Transcription de l`audience du 14 mai 2015

Transcription

Canadian Nuclear
Safety Commission
Commission canadienne de
sûreté nucléaire
Public hearing
Audience publique
May 14th, 2015
Le 14 mai 2015
Best Western Pembroke Inn
& Conference Centre
1 International Drive
Pembroke, Ontario
Best Western Pembroke Inn
& Conference Centre
1 promenade International
Pembroke (Ontario)
Commission Members present
Commissaires présents
Dr. Michael Binder
Mr. Dan Tolgyesi
Dr. Sandy McEwan
Ms Rumina Velshi
Mr. André Harvey
M. Michael Binder
M. Dan Tolgyesi
Dr Sandy McEwan
Mme Rumina Velshi
M. André Harvey
Secretary:
Secrétaire:
Mr. Marc Leblanc
M. Marc Leblanc
General Counsel:
Avocate générale :
Ms Lisa Thiele
Me Lisa Thiele
613-521-0703
StenoTran
www.stenotran.com
ii
TABLE OF CONTENTS PAGE Opening remarks
1 CMD 15-H.A
Adoption of Agenda 4 CMD 15-H5.1/15-H5.1A/15-H5.1B
Oral presentation by SRB Technologies (Canada) Inc. 8 CMD 15-H5/15-H5.A
Oral presentation by CNSC staff 35 CMD 15-H5.2
Oral presentation by
Lake Ontario Waterkeeper and Ottawa Riverkeeper 66 CMD 15-H5.3
Oral presentation by Brant Ulsh 110 CMD 15-H5.4/15-H5.4A/15-H5.4B
Concerned Citizens of Renfrew County 138 CMD 15-H5.7
Oral presentation by Prevent Cancer Now 180 CMD 15-H5.8/15-H5.8A
Oral presentation by First Six Years 200 CMD 15-H5.9/15-H5.9A
Oral presentation by Ms Janet McNeill 239 CMD 15-H5.10/15-H5.10A/15-H5.10B
Presentation from Kelly O'Grady 254 CMD 15-H5.11
Canadian Coalition for Nuclear Responsibility 285 CMD 15-H5.5
Written submission from Zach Ruiter 307 iii
TABLE OF CONTENTS PAGE CMD 15-H5.12
Written submission from Dr. Judith Deutsch 311 CMD 15-H5.14
Written submission from Terry Lapierre, Chief Administrative Officer, the City of
Pembroke 314 CMD 15-H5.16
Written submission from the Security Company 315 CMD 15-H5.17
Written submission from Algonquin College 317 CMD 15-H5.20
Written submission from City of Pembroke Fire Department 319 CMD 15-H5.21
Written submission from Isolite 323 CMD 15-H5.22
Written submission from Main Street Community Services 325 CMD 15-H5.23
Written submission from Peter Emon, Warden of the County of Renfrew 326 CMD 15-H5.24
Written submission from Ron Gervais, Deputy Mayor, City of Pembroke 326 CMD 15-H5.25
Written submission from John Yakabuski, M.P.P., Renfrew-Nipissing-Pembroke 326 CMD 15-H5.26
Written submission from Harrington Mechanical Ltd. 327 CMD 15-H5.27
Written submission from A. Bucholtz 327 iv
Written submission from Garry Amyotte 328 CMD 15-H5.29
Written submission from Steel Fire Equipment 328 CMD 15-H5.30
Written submission from Monika Schaefer 329 CMD 15-H5.31
Written submission from International Physicians for the Prevention of Nuclear War 330 CMD 15-H5.32
Written submission from Ken Collier 334 CMD 15-H5.33
Written submission from James Deutsch 334 CMD 15-H5.34
Written submission from Coalition for a Nuclear Free Great Lakes 335 CMD 15-H5.35
Written submission from Kelly and Roger Goldberg 335 CMD 15-H5.36
Written submission from Community Living Upper Ottawa Valley 336 CMD 15-H5.38
Written submission from Canadian Nuclear Association 336 CMD 15-H5.37
Written submission from Darlene Buckingham 336 CMD 15-H5.39
Written submission from Seiler Instrument & Mfg Co., Inc. 337 v
Written submission from James Penna 337 CMD 15-H5.41
Written submission from Ed Jacyno 337 CMD 15-H5.42
Written submission from BETALIGHT B.V. 337 CMD 15-H5.43
Written submission from Gilles Provost 338 CMD 15-H5.44
Written submission from Dorothy Goldin Rosenberg 338 CMD 15-H5.45
Written submission from Siegfried (Ziggy) Kleinau 338 CMD 15-H5.46
Written submission from Jo Hayward Haines 339 1 Pembroke, Ontario
--- Upon commencing on Thursday, May 14, 2015
at 9:03 a.m. / L'audience débute le jeudi
14 mai 2015 à 9 h 03
Opening remarks
M. LEBLANC : Good morning, ladies and
gentlemen.
Bonjour à tous.
Welcome to the public hearing
of the Canadian Nuclear Safety Commission.
The Canadian Nuclear Safety Commission is
about to start the public hearing on the application by SRB
Technologies (Canada) Inc. for the renewal of the nuclear
substance processing facility operating licence for its
facility located in Pembroke, Ontario.
During today's business, we have
simultaneous translation in English and French.
Des appareils de traduction sont
disponibles à la réception.
La version française est au
poste 2 and the English version is on channel 1.
We would ask that you please keep the pace
of your speech relatively slow so that the translators have
a chance to keep up.
L’audience est enregistrée et transcrite
textuellement; la transcription se fait dans l’une ou
2 l’autre des langues officielles compte tenu de la langue
utilisée par le participant à l'audience publique.
I’d also like to note that this hearing is
being video webcast live and that the hearing is also
archived on our web site for a three-month period after the
closure of the hearing.
The transcripts will be available
on our web site in about 10 to 14 days.
To make the transcripts as meaningful as
possible, we would ask everyone to identify themselves
before speaking and, as a courtesy to others in the room,
please silence your cell phones and other electronic
devices.
Monsieur Binder, président et premier
dirigeant de la CCSN, présidera l’audience publique
d'aujourd'hui.
Mr. President.
LE PRÉSIDENT : Merci, Marc.
And good
morning, and welcome to this particular hearing.
First of all, I'd like to tell you, on
behalf of the Commissioners here, how delighted we are to
be here today in Pembroke, outside of Ottawa.
Any excuse
to escape Ottawa is good, so we are really happy to be here
and to give opportunity for intervenors to express their
views about what is being discussed here today.
I'd also like to thank the hotel for the
facilities that they provide us with.
3 As Marc said, this is -- I'd like to
welcome all of you joining us through the webcast, and I
think there will be some teleconferencing with some
intervenors.
My name is Michael Binder, I am the
President of the Canadian Nuclear Safety Commission.
And I'm going to introduce today the
members of the Commission.
On my right is Mr. Dan Tolgyesi, and on my
left is Dr. Sandy McEwan, Ms Rumina Velshi and Mr. André
Harvey.
We have heard our Secretary, Secretary to
the Commission, Marc Leblanc, and we also have with us here
today Ms Lisa Thiele, Senior General Counsel to the
Commission.
M. LEBLANC:
The initial Notice of Public
Hearing -- oh, still for you, I think.
the agenda.
We have to adopt
Sorry.
THE PRESIDENT:
Okay.
So I'd like to call
for the adoption of the agenda as described in CMD 15-H4.A.
Do we have concurrence?
record, the agenda is adopted.
So for the
4 CMD 15-H.A
Adoption of Agenda
THE PRESIDENT:
M. LEBLANC:
Marc?
Thank you.
The initial Notice of Public Hearing
2015-H-01 was published on November 14, 2014 to announce
the opportunity for participant funding for intervenors,
and revised notices were published on February 24th and
April 23rd of this year to indicate the location and exact
date for the hearing.
Submissions from SRBT and CNSC staff were
due on March 13, 2015, and the public was invited to
participate either by oral presentation or written
submission.
April 13 was the deadline set for
intervenors.
intervention.
The Commission received 46 requests for
One request was received significantly after
the deadline and was denied. Another one was denied as it
was not specific to the SRBT renewal application.
May 6 was the deadline for filing of
supplementary information.
We note that presentations have
been filed by CNSC staff, SRBT, as well as by intervenors.
Participant funding was available to
intervenors to prepare for and participate in this public
5 hearing.
Three groups or individuals participating today
are receiving funding.
The funding decision is available
on the CNSC web site.
All documents are available at the
reception, either on CDs or in paper format, as well as the
Commission Members’ biographies.
I would like to make other introductory
remarks.
We are in Pembroke today to consider the
written submissions and oral presentations from a large
number of citizens and organizations who wish to express
their opinions in the context of the SRBT renewal hearing.
I wish to emphasize that the Commission is
a quasi-judicial administrative tribunal, and that,
consequently, it is independent from any political,
governmental or private sector influence.
In fact, each
Commission Member is independent of one another and also
independent of the CNSC staff.
Interventions that are filed this -- for
this hearing include recommendations to the Commission.
CNSC staff also make recommendations to the Commission, but
it is the Commission Members who will render a decision
based on all the evidence presented in the context of the
hearing process.
The Commission Members are appointed by
6 the Governor-in-Council on the basis of their achievements
in their respective fields of endeavour as well as their
excellent reputations among their peers.
Their mandate is simple:
ensure that the
use of nuclear is done in a manner that protects the
environment as well as the health, safety and security of
the workers and the public.
I would also like to emphasize that the
CNSC has no economic mandate and will not base its decision
on the economic impact of the facility.
Finally, as I stated earlier, the
Commission is an administrative tribunal.
It is willing to
conduct this hearing in the affected community and to
provide a forum where members of the public can express
their views on the matter at hand.
As the Commission is a tribunal and wishes
to hear all 10 verbal presentations and ask as many
questions as it deems necessary on these and the 36 other
written submissions, we ask that everyone respects the
decorum of the tribunal setting and assists with the
orderly, civil and respectful conduct of this proceeding.
The Commission will not tolerate
inappropriate behaviour and will take measures necessary to
ensure the orderly conduct of this proceeding in the same
way it does for all other proceedings it conducts in Ottawa
7 and in the communities.
The way we will proceed today is that we
will first hear the presentations by SRBT and CNSC staff,
followed by the presentations from intervenors, in the
order that is listed on the agenda.
I mentioned earlier that 10 intervenors
are scheduled to present verbally today.
And while the
presentations are limited to 10 minutes, Commission Members
will have the opportunity to ask questions after each
presentation.
And no time limit has been ascribed for the
question period.
To help you in managing your time, a timer
system is being used today.
The light will turn yellow
when there is one minute left and turn red and beep at the
10-minute mark.
It, in fact, will also beep at the
one-minute left to assist you in planning your time.
We will be addressing the written
submissions after the oral presentations.
Written
submissions from people who choose not to make oral
presentation are very important to this review.
These
written submissions are being carefully considered and we
will address each of them before the close of the hearing.
There will be a final round of questions
from the Commission Members at the end of the day.
8 The break for lunch will be at
approximately 12:30 today for a period of one hour, and
there will be short breaks in mid-morning and in the
afternoon.
Your key contact persons will be Ms.
Louise Levert and Ms. Johanne Villeneuve from the
Secretariat staff and you will see them going around or at
the back of the room, where they are at the moment, if you
need information regarding the timing of presentations,
documents, et cetera.
Mr. President.
THE PRESIDENT:
Okay.
Thank you, Marc.
I would like to start the hearing by
calling on the presentation from SRB Technologies Inc., as
outlined in Commission Member Documents 15-H5.1 and H5.1A
and .B.
I understand Mr. Levesque will make the
presentation.
Over to you, sir.
CMD 15-H5.1/15-H5.1A/15-H5.1B Oral presentation by SRB Technologies (Canada) Inc.
MR. LEVESQUE:
Thank you very much,
President Binder and other members of the Commission.
name is Stephane Levesque.
I am the president for SRB
My
9 Technologies and I will be making the presentation today,
and I am joined by our Vice President, Ross Fitzpatrick,
who will help me answer some questions; our manager at
Health Physics and Regulatory Affairs, Jamie MacDonald; our
Project Engineering, Courtney Sinclair, and immediately
behind me, Doug McNab, Independent consultant that we have
retained.
SRB Technologies has been in operation
since 1990 and currently employs 46 people.
We are located
in an industrial park on the outskirts of Pembroke and we
lease 12,000 square feet of a building that's shared with
two other tenants.
The closest residence is approximately
250 metres from our facility.
SRB is licensed by the CNSC to process
tritium for the manufacturing of gaseous tritium light
sources, which are glass capsules coated with luminescent
powder and filled with tritium.
The interaction between
the particles emitted by the tritium and the luminescent
coating produces light on a continuous basis.
Our products ensure the safety and
security of people all over the world.
We are a supplier
of aircraft science for many aerospace manufacturers,
including Boeing, Canada Air, Beechcraft, and Learjet.
We
manufacture many vital products used by the Canadian and
other NATO peace-keeping troops worldwide, including the
10 U.S. military, and as you can see from the picture in
Figure C, the U.K. Ministry of defence, where you actually
see Prince Harry using one of our products on deployment.
Other lighting technologies require
wiring, power, or batteries.
Our lighting products do not
use electricity, thereby reducing energy consumption.
SRBT requests that the Commission renew
our operating licence for a period of 10 years.
We are
requesting a licence with no new methods or processes and
we will be operating our existing equipment with the same
trained staff.
We request a licence with the same licence
activities, the same release limits, the same action level,
and the same possession limits.
Our renewal request is based upon our
positive compliance history and safety record.
Our
facility was operated safely throughout the current
licence.
Our total air emissions were less than 18 percent
of the licence limit.
Our liquid emissions were less than
7 percent of the licence limit.
The maximum dose to any of
our workers in a given year was less than 2 milliSieverts.
The maximum dose to a member of the public in any year was
less than .007 milliSievert, which is less than 1 percent
of the public dose limit.
And we have only had one single
lost time injury in the last licence period.
11 Our renewal request is based upon our
stable and experienced workforce.
Fourteen of the 15 staff
that were employed in 2010 continue to work at the facility
in the exact same positions.
The other individual, the
fifteenth one, has been appointed in a new position created
called Compliance Manager that audits our processes and
procedures on a continuous basis.
Despite our growth, our
workforce average is nearly nine years of experience at the
facility and the average age of just over 40 years old.
Members of our Health Physics Team possess
a combined of 107 person years working at SRB, which
approximately averages 15 years per the seven members that
we have in the Health Physics Team.
Myself, the president,
and vice president, Ross Fitzpatrick, now own the company,
have a combined 42 years of experience managing and
operating the facility.
Our renewal request is based upon our
safety-related programs and processes.
Programs and
processes continue to undergo continuous review,
improvement, and revision.
Several new CNSC regulatory
documents and CSA standards are being integrated in our
management systems.
Continuous improvement remains a key
priority.
Our renewal request is based upon the
success of our emission-reduction initiatives.
Tritium
12 production has increased approximately four and a half
times over the licence term, for releases to atmosphere
have risen at less than half the rate of production.
Therefore, the ratio of tritium release versus process
continues to be driven down.
Our renewal request is also based upon
public perception.
We have had very little concerns
expressed over the current licence period.
Our public
information program will ensure that regular public input
is facilitated and considered in lieu of hearings.
Regular
meetings with all stakeholders would continue to take place
as required and will continue an open flow of information
between parties.
Our products are crucial to ensure the
safety and security of people all over the world.
Without
our products, some companies would need to redesign their
products at considerable cost.
I would like to take this
opportunity to ask you next time that you fly on a plane to
look at the emergency doors and specifically at the door
handle or latch on the door.
Imagine aerospace companies
having to redesign, test, and re-qualify their emergency
doors to take in other products.
It would force the use of
inferior lighting technologies requiring wiring, power of
batteries, resulting in lack of reliability, portability,
in some cases safety.
Military aerospace and commercial
13 organizations choose our products because they are safe,
reliable and highly effective.
The sale of tritium light sources and
products represent the sole source of revenue for SRB,
including the after-sale service of taking back expired
products.
And contrary to comments from some of the
interveners, the revenue associated with this practice in
2014 was 9 percent of our revenue and only 6 percent so far
in 2015.
A 10 year licence term would allow
resources to be focused on research to further reduce
emissions, rather than to relicensing.
You can imagine the
resources involved in relicensing for a small company like
us.
It will help us attract higher and retain
highly qualified staff to support business growth and
safety.
Staff are more likely to join or stay at our
facility when the future of the company is secure with our
long-term licence.
It would assist us in securing long-term
contracts with customers and suppliers.
It would allow
customers to design our products in their application for a
long term.
It would also allow suppliers to provide us
beneficial terms for long-term supply contracts.
14 It would allow us to support planning of
facility improvements and dedication of a fixed part of our
revenue to emission reduction initiatives.
It would also
increase access to financing for equipment and training.
You can also understand our banks are more likely to give
loans when the future of the company is secure with a
long-term licence, loans for emission reduction initiatives
equipment or so on.
Our management system is comprised of
programs, procedures, and associated documents that are in
place with the purpose of meeting the Nuclear Safety
Control Act, regulations and conditions of a licence.
SRB has analyzed several new or modernized
standards in regulatory documents.
Safety programs are
continually improved to meet or exceed these evolving
requirements, including CSA N292 on radioactive waste; CSA
N393 on Fire Protection; Reg. Doc 2.2.2 on Personnel
Training; Reg. Doc 2.10.1 on Emergency Preparedness;
RD/GD-210 for Maintenance Programs for Nuclear Power
Plants; RD/GD-99.3 on Public Information and Disclosure;
CSA N294 on Decommissioning, and, lastly, CSA N286 on
Management system.
Regarding this last standard, SRB has
analyzed its current management system and established an
action plan to become compliant with CSA N286.
15 As an initial step, the SRBT Quality
Manual, which governs and defines our key processes,
management responsibilities and accountabilities, was
revised in September 2014 to reflect organizational
improvements and to provide greater clarity.
SRBT fully
expects to meet the requirements of N286 by the end of 2016
and we continue to keep CNSC staff informed of our progress
towards this goal.
This is the organizational structure
that's in place at the facility to meet the conditions of
the licence, the Nuclear Safety Control Act, and the
regulations:
Over the term of the current licence, a
number of organizational improvements have been made.
In
2012 we have added an Import and Export Specialist to
support our Import and Export Manager.
We have hired a
Health and Safety Specialist with expertise in that
specific area.
We have hired a Project Engineer that
worked in another CNSC-licensed facility for over two
years.
We, as I have discussed before, basically created a
position of Compliance Manager, an individual that audits
the facility over the course of the areas is their sole
task, and they have worked at SRB in various capacities
before that in management and in Health Physics for 16
years.
In 2014 we also added a Manager of Health Physics
16 and Regulatory Affairs.
This individual worked at SRBT for
just over five years before moving to another CNSC-licensed
facility for two years, and worked for the CNSC as an
inspector conducting inspections for nearly six years in a
wide variety of areas.
In 2014 we also hired a full-time
consultant that worked for the CNSC for over 30 years in
various capacities.
This individual was also intimately
involved in the Decommissioning of Shield Source.
And in
2015, in April, we recently added a Design Engineer.
Our organization includes committees which
deal with specific areas affecting safety and that are
instrumental in the development and refinement of programs
and procedures.
You can see in our written submission that
we had as many as 91 committee meetings in 2014 and so far
we have had 35 in 2015.
In 2014 we also added two new
committees, a Production Committee.
And to help us
implement Reg. Doc 2.2.2 on staff training, we have also
instituted a new Training Committee.
Various performance assessment,
improvements and management revenues take place at the
facility.
Throughout the term of our current licence, CNSC
staff conducted several compliance inspections, facility
visits, and promotional visits.
And I'm proud to say that
as of today all "action opens" have been addressed, so
there's no open actions as a result of any of these
17 inspections.
We also have additional independent
oversight.
Annually we have audits by our ISO 9001
Registrar BSI management system.
We've always had internal
audits, but now with the addition of the compliance
manager, we're having even more frequent internal audits,
and actually 18 are planned in 2015, covering all safety
control areas.
Over the licence term we've had three
audits by Ontario Power Generation.
We've had annual
inspections by the Pembroke Fire Department.
As required
by our licence, we also had annual inspections by the fire
protection consultants.
A number of our products are
UL-approved -- or some would know as Underwriter
Laboratories -- and as a result of that we have quarterly
unannounced inspections by UL to make sure that the
products are made to requirements.
You can also understand that with the many
aerospace and military companies that we supply that we
have had numerous customer audits as well.
All and any issues identified during these
inspections, much like the CNSC inspections, and audits are
promptly addressed.
We have always effectively trained our
18 employees in all key aspects of our licence activities and
our operation.
As previously mentioned, REGDOC 2.2.2 on
Personnel Training was published by the CNSC in August
2014.
As a result, as briefly mentioned, we first
appointed a new Training Committee to manage a transition
to this new standard.
We've then undertaken a comprehensive
analysis of all our processes to determine the activities
that would require to be trained systematically.
We then
developed a Training Program Manual which was accepted by
CNSC staff in March 2015.
The inaugural cycle of the
training program is scheduled for completion by the end of
2016.
We have other key training activities.
Radiation protection training is being
given to all new staff that we hire at the facility.
That's whether they work in an area that handles nuclear
substances or in the office:
any single member that works
at SRB takes radiation protection training.
In addition to that, we have yearly
radiation protection training that's mandatory for all
staff -- again, whether you're handling nuclear substances
or not.
And that even includes myself, the president and
owner of the company.
19 The Pembroke Fire Department performs
yearly fire extinguisher training for all our staff.
some first responder training.
We do
We have an external company
that basically trains our staff that are involved with
shipping and receiving packages and DGT.
We receive health
physics training and we do a lot of cross-training between
the seven members of our health-physics team.
protection committee member training.
We have fire
We have two
committee members that are actually volunteers for two
different communities and they receive extensive training
as part of being volunteers.
We've also received a lot of
external training in health and safety.
We've continued to safely operate our
Class 1B nuclear facility throughout the term of the
licence period.
We've added key expertise as I discussed
in critical safety areas, and our programs and processes
continue to evolve to meet regulatory requirements.
We continuously analyze, report, and trend
our operating performance.
We submit quarterly reports to
CNSC staff in environmental monitoring.
We submit monthly
reports again to CNSC staff on groundwater monitoring.
We
submit annual reports under our dosimetry licence, and we
meet all our reporting requirements on export and export
licensing.
And we also have an Annual Compliance
20 Report that's also submitted to CNSC staff each year.
This
Annual Compliance Report is also posted on our website.
The information used on this Annual Compliance Report and
that of others in our section, other facilities, is used by
the CNSC to produce the Annual Report on the Performance of
Canadian Uranium Fuel Cycle and Processing Facilities.
it's important that people know that.
And
Members of the
public have and can provide written comments at these
yearly meetings that present this data.
SRB will continue
to be in attendance and be available to answer questions of
the Commission during these meetings.
In the future, we will also take the
annual report and publish it on the SRB website.
So not
just our Annual Compliance Report, but also the report of
the CNSC, well in advance of these meetings for the public
to obtain.
The overall design basis of key
structures, systems, and components relating to the
facility and our licensed activities and relating to safety
has not changed.
Some component modifications have
improved safety and reliability and reduced the
environmental impact of our operations.
The same
modifications to key safety-related equipment have been
implemented in a controlled fashion, including risk
assessment, commissioning and testing plans, and
21 consideration of training.
Structures, systems, and components are
maintained fit for service, and during the term of the
current licence there were no significant equipment
failures that presented a safety issue.
Ventilation systems were maintained fully
operational.
Stack flow performance was independently
verified annually against design requirements.
Liquid
scintillation counters were maintained annually, and two
new units were purchased, installed, and commissioned.
We've added five new portable tritium and area monitors,
one of which is kept at the Pembroke Fire Department.
We've increased the number of stationary monitors by two,
one in use and one that's kept as a spare.
And the weather
station was maintained as required.
SRBT took several actions as a result of
the lessons learned at Shield Source Incorporated, formerly
our competitor.
This is where Shield Source was found to
have issues monitoring their air emissions.
As a result of
these findings, SRB has elected to increase the frequency
of stack monitoring verification from every two years to
every year.
We've invested a considerable amount of money
upgrading and modernizing our equipment that had been
purchased in 2005 and '06 that's associated with stack
monitoring by purchasing and installing new "bubblers," new
22 tritium monitors for real-time emissions monitoring, and a
new digital data recorder to complement the existing
analogue paper chart recorder that we had.
The annual dose to our workers has been
less than the regulatory limit of 50 millisieverts, and
actually less than 1 millisievert in 2010 and '12.
You can
see the highest is in 2013 at 1.93, with the highest
average as .25 -- and again, well below the limit of 50
millisieverts.
The maximum dose to a member of the public
is also well below the regulatory limit of 1 millisievert.
The highest over the licence period was in 2013 and stands
at 0.0068 millisieverts, compared to the limit of 1
millisievert, which actually represents less than one per
cent of the public dose limit.
Our lost time incidents over the licence
period:
2011.
we've only had one of them, as you can see, in
And it was in an area where no radiological
activities took place.
We continue to implement
improvements to ensure safety.
Over 30 per cent of our
employees are trained in emergency first aid and are
trained to use the automatic electronic defibrillators.
The annual emissions of HTO, which is
tritium oxide, and tritium gas were maintained at less than
18 per cent of the licence limit.
And just let me remind
23 you that's despite increasing production over our licence
term by four and a half times.
The annual emissions of HTO, which is the
greatest contributor to public dose, were also maintained
less than 27 per cent of the licence limit and again
despite increasing production by four and a half times.
If you look at Table E briefly, you can
see the numbers on the amount of tritium that we processed
against what we released over the licence period.
And when
we actually look to see how well we're doing in reducing
emissions, we looked at the released process ratio.
And
you can see that that, over the term of the licence, has
gone down.
And if I look at it specifically on Table F,
you can see that where it stands at .23 in 2014, in 2010
and '11 it was .55 and .76.
SRB has been successful in reducing this
ratio over the last several years.
cent in 2008.
It was actually 1.7 per
So what that means in 2008 we were releasing
1.7 per cent of everything we were processing, down to now,
.23, so less than a quarter of a per cent in 2014.
And I'm
happy to say that although the presentation says 16 weeks,
now 17 weeks running in 2015 the ratio now stands at .15.
So we're looking so far at another reduction this year.
This ratio is an excellent indicator of
the overall effectiveness of our emission reduction
24 initiatives.
Throughout the term of the existing
licence, our liquid emissions were also maintained well
below the licence limit at less than seven per cent of the
actual licence limit, the highest being actually 6.5 per
cent.
We've had a groundwater monitoring program
in place since 2006 that includes a sampling by a third
party of 46 wells.
The highest average concentration in
one of the residential wells that we monitor in 2014 was
217 becquerels per litre and continues to trend downward.
The concentration is well below the Ontario Drinking Water
Guideline value of 7,000.
Of the 34 monitoring wells at the end of
2014, only two wells exceeded the Ontario Drinking Water
Guideline value.
Eight wells, as a comparison, exceeded
this Guideline in 2007 compared to two now.
Both of these
wells are located on site within 50 metres of the stack.
Actually, one is directly at the stack.
The concentrations are expected to
gradually decrease with decay, hydrogeological processes,
and dilution due to rain.
And we will continue to not do
any tritium processing operations during precipitation
events as a means of further protecting groundwater.
An independent third party also collects
25 and analyzes samples as dictated by SRB's environmental
monitoring program.
We have 40 air monitoring stations
that are located within two kilometres of the facility.
We
have eight precipitation monitors that are located between
250 and 500 metres from the facility.
A third party takes produce sampling from
both local gardens and the local market.
sampled on a quarterly basis.
Local milk is
Local wine is sampled at a
brew-your-own place next to our facility.
And the Muskrat
River, which is located a few hundred metres from the
facility, is sampled on a monthly basis unless frozen, and
the concentrations are always near detection level.
All this data is used to calculate
whatever quarter of the year the maximum dose to a member
of the public as a result of the emissions from SRB.
And
when I relate to "maximum," is in calculating this dose we
assume that an individual works right next door to our
facility and breaths that air and lives right in the
neighbourhood, right closest to SRB and breaths that air
and doesn't go anywhere else between, other than work and
home.
We assume that they consume only
vegetables from the highest local garden that we've sampled
and the local market and we assume, although Pembroke is on
municipal city water, that they use a well that has the
26 concentrations that we've discussed.
So it's our worst case scenarios and it
still gives you a dose of .0068 at maximum, so again, less
that one per cent of the public dose limit.
On fire protection, our Fire Protection
Committee meets at least every quarter.
Our program was
revised three times during the licence term and we
performed a Gap Analysis against a new CSA
N393 standard
on fire protections, our facilities that process, handle,
store nuclear substances and we've developed an action plan
that was accepted by CNSC staff and the new program will be
submitted in July, 2015.
We perform quarterly maintenance of the
facility's sprinkler system and we perform monthly fire
protection equipment inspections.
We've had at least five fire drills each
year during the current licence term.
SRB has developed, implemented and
maintained an Emergency Plan.
The Emergency Plan was
revised twice during the licence term and once as a result
of the lessons learned from the disaster of Fukushima.
We then performed a Gap Analysis between
our Emergency Plan and the new REGDOC 2.10.1 on nuclear
emergency preparedness and response.
We submitted an
Action Plan which was accepted by CNSC staff with a
27 revision that the Emergency Plan which will be completed by
September, 2015.
SRB also conducted a full-scale emergency
training exercise on February 9th, 2015.
It was conducted
in concert with the Pembroke Fire Department, the City of
Pembroke and was observed by several CNSC staff.
During
this exercise, we simulated an emergency situation in Zone
2 where tritium light sources are installed in and safety
signs and devices.
The response was deemed acceptable with
all regulatory requirements being met.
SRB identified only
improvement opportunities, but no safety concern.
The latest revision of our Waste
Management Program was accepted by CNSC staff on March 3rd,
2015.
We've expanded the procedures that focus on
processes outlined in CSA N292.
Between 2010 and 2014, SRB made 23
low-level waste consignments to licensed waste management
facilities.
I'd like to clarify at this point some of
the concerns voiced by intervenors.
Any expired light
source that we have is sent to a licensed waste facility
and not to landfill.
So that's any expired light source.
All waste shipments are also reported as
part of our annual Compliance Report and, again, waste is
not stored at SRB Technologies, waste is only temporarily
28 stored in our waste room which is a small room that's about
seven feet by six and waste is shipped from it every couple
of months.
Our Waste Management Committee is focused
on reducing all type of facility waste generation.
We've had no security-related events
throughout the current licence term.
SRB continues to
maintain the Security Program in accordance with the
regulatory requirements and expectations.
We've had
several security enhancements and upgrades to improve the
nuclear security that were made over licence period.
Maintenance of the security system is
performed by an independent third party at least every six
months and all and any minor issues that have been
identified during physical security inspections by CNSC
staff are promptly addressed.
In addition to tritium processing, SRB
possesses, uses, stores and manages an extremely small
quantity of depleted uranium.
We presently have less than
six kilograms on site, with approximately 3.3 kilograms in
loose form, but the balance of it is being used in our
containers that store and dispense tritium in our gas
lights.
We're required to obtain import and export
licences for international shipments.
All requirements
29 relating to import and export licences continue to be met.
Regarding our import licences, we have to
report at the end of each licence, except for the U.S.A.
where we do it on a yearly basis, all the imports to the
CNSC.
Regarding export, we're required also
yearly, or depending on the licence, at the end of the
licence to report all the exports associated.
In 2014, 1,122 shipments of product were
made to 19 countries.
Approximately 90 per cent of our
shipments are destined for customers in Canada or the U.S.
No transport incidents involving our packages have occurred
over the licence term and SRB continues to comply with all
requirements.
Due to the comments expressed by a number
of intervenors in the submissions, we will include all
import and export of tritium by country in future annual
Compliance Reports and this information will be posted on
our website.
So again, any import that we do and export
will be reported by country in future annual Compliance
Reports on a yearly basis.
Plant tours have proven to be a useful
tool to reach the public.
Ninety-eight plant tours were
conducted between 2011 when we started tracking them and
the end of 2014 and so far we actually had 30 tours in
30 2015.
Up until the end of 2014, we only received
two inquiries from members of the public during the current
licence term.
Information pamphlet and licence renewal
information was sent to various stakeholders, including
those living within 500 metres of the facility.
As a
result, we've had very little to no concerns expressed.
We've also sent the same information
pamphlet, which I have here today and I can make available
for the public or members of the Commission, to 10,000
residences -Excuse me.
We sent the same information pamphlet
later to 10,000 residences and businesses and
establishments in Pembroke and neighbouring Laurentian
Valley.
As a result of sending these 10,000 pamphlets, we
received one e-mail with questions which we responded to.
We've also performed a door-to-door
campaign of 369 residences within four kilometres of our
facility.
Seven individuals that were at home expressed
very little to no concern.
We can also provide any information to any
members of the public, including the recent interventions
that we received, even if they don't live in our local
community.
I just need to be provided their contact
31 details or they can request it and we can send it to them.
Our revised Public Information Program was
made to address comments received by CNSC staff and to
reflect requirements of RD/GD-99.3.
In October, 2014,
staff approved this Public Information Program and deemed
it fully satisfactory.
We have a Public Information Committee
that manages the program throughout the term of the current
licence.
Meetings are held quarterly to discuss public
opinion, media coverage and discuss Public Information
Program and Public Disclosure Protocol.
The former Mayor
of Pembroke, who served Pembroke for 18 years, including
three terms as Mayor and two terms as Deputy Mayor, is now
employed by SRB and is now a member of this Committee.
We also recently invited members of the
Concerned Citizens of Renfrew County and the First Six
Years Organization when they took part in a tour of our
facility to be part of our Committee and I understand that
Ms O'Grady from the First Six Years will take part.
Our website was frequently updated
throughout the current licence term.
We recently
completely redesigned our site, and if I can draw your
attention to Figure K on the screen now, you can see that
there's a tab where public notifications, that's marked in
red, where information's regularly posted.
This includes
32 information like my presentation today, our written
submissions, our licence application and actually we posted
the CNSC submission.
We also have an area where we post the
Licence and Licence Condition Handbook.
We post all our
annual Compliance Reports, our Addendums.
We post our
monitoring results, we provide details of presentations
like I did to City Hall and we provide information on
tritium and radiation.
We also recently added an area to
provide information on emergency preparedness.
For
example, the Report that was provided as a result of the
exercise is now linkable and obtainable on the website.
We also have a number of public
involvement initiatives and community support that we post
on there.
You'll see at the bottom right of the
picture that our Facebook page was recently developed and
linked to the website.
We first started using it to notify
members of the public of the emergency exercise, but now
we're using it for other things.
SRBT complied with the repayment schedule
stipulated in our current licence regarding cost recovery.
The final payment and cost adjustment was paid on September
25th, 2013.
Regular payments are now made and SRB is in
full compliance with the cost recovery fee regulations.
33 We have a CNSC approved financial
guarantee which was approved on June 26, 2008.
Based on
the previous revision of our PDP, Preliminary
Decommissioning Plan.
The final instalment was made in
April, 2014 which brought an account held in escrow to just
over $550,000 and continues to build interest.
SRB has no
access to these funds, it's only the escrow agent and the
CNSC that would be able to get the money.
Following the closure of Shield Source and
their decommissioning, SRB actually hired the contractors
that were directly involved with decommissioning the Shield
Source, RadSafe and Mr. McNab here today.
With the information, we revised our PDP,
our plan, in late 2014 to make sure we have any activities
that we haven't thought of in the original one based on
what was found in the Shield Source and now requires us to
increase our financial guarantee by just over $102,000 for
a total of just over $652,000.
We propose as part of this licence to have
six equal payments of $17,000 to be made every six months
to the existing escrow account beginning in October, 2015.
In our future outlook we're committed to
product development in safety applications only where we
use our products with a focus on contributing to the safety
of people in situations where reliable illumination is
34 needed.
We're committed to no less than five per
cent of our annual profit over our new licence term to
researching and implementing emission reduction strategies
and technologies.
We're committed to integration with the
scientific and nuclear community to advance education,
emission reduction and environmental monitoring
initiatives.
We are also committed to the reduction of
occupational doses, strive to lower the dose to all our
workers well below the public dose limit of 1 mSv.
In conclusion, throughout the term of the
current licence, SRBT has operated the facility safely and
in accordance with the provisions of the licence and
Nuclear Safety and Control Act and Regulations.
SRB has
demonstrated its commitment and integrity by the work
described in this submission.
SRB has demonstrated that it will continue
to make improvements in the future by the various
initiatives, goals and targets described in this submission
and based on important concerns raised by the CNSC, members
of the public, and our employees.
We therefore believe that under section
24(4) of the Nuclear Safety Control and Act SRBT is
qualified to carryon the activity for which it has applied.
35 And will, in carrying on that activity, make adequate
provisions for the protection of the environment, the
health and safety of persons, and the maintenance of
national security and measures required to implement
international obligations to which Canada has agreed.
Thank you very much.
MR. LEBLANC:
Mr. Levesque, if you can
provide a copy of the pamphlet to Madam Levert so it can be
part of the record?
Thank you.
MR. LEVESQUE:
record.
Stephane Levesque, for the
Okay.
THE PRESIDENT:
Thank you.
I would like now to move to a presentation
by CNSC Staff as outlined in CMD 15-H5 and H5.A.
I understand that Dr. Newland will make
the presentation.
Over to you.
CMD 15-H5/15-H5.A
Oral presentation by CNSC staff
DR. NEWLAND:
Thank you.
Good morning everyone, good morning, Mr.
President, Members of the Commission.
My name is David
Newland and I am the Acting Director General of the
Directorate of Nuclear Cycle and Facilities Regulation.
36 With me today is Mr. Michael Rinker,
Director of the Nuclear Processing Facilities Division.
We
also have licensing and compliance staff as well as subject
matter experts with us to help answer any questions that
the Commission Members may have.
We are here today to present Commission
Member Document CMD-15-H5 entitled, A Licence Renewal, SRB
Technologies (Canada) Inc.
I will now pass the presentation to Mr.
Michael Rinker, thank you.
MR. RINKER:
and Members of the Commission.
Good morning, Mr. President
My name is Michael Rinker
and I am the Director of the Nuclear Processing Facilities
Division at the CNSC.
The purpose of this presentation is to
provide CNSC Staff recommendations on the licence
application from SRB Technologies (Canada) Inc., or SRB,
for renewal of its nuclear processing facility operating
licence.
To support the CNSC Staff recommendation I
will present highlights of the CNSC regulatory oversight of
this facility, the performance of the facility over its
licence term, areas of regulatory focus and other matters
of regulatory interest.
And finally, I will present the
CNSC Staff recommendations to the Commission on this
37 licensing matter.
SRB is a gaseous tritium light source
manufacturing facility located in Pembroke, Ontario.
SRB
leases a space in an industrial building similar in size
and appearance to a strip mall that is located on the
outskirts of Pembroke.
As you have just heard, SRB manufactures
several types of radiation devices for military and
aerospace applications.
SRB also manufactures emergency
lighting devices such as exit signs, safety markers and
safety signs that are found in public places.
The devices are commonly used for
emergency lighting where the uses of conventional
electrical lighting is unavailable or impractical. The
current SRB nuclear substance processing facility operating
licence expires on June 30th, 2015.
10-year licence.
SRB has requested a
No new activities are proposed that are
not currently authorized under the current licence.
SRB has requested to increase the
footprint of the facility by 180 square metres to
accommodate the storage of non-radiological materials.
This slide provides a timeline of
licensing actions related to the SRB facility.
In 1990
Saunders-Roe (Canada) Inc., now SRB, was issued a
radioisotope licence by the Atomic Energy Control Board to
38 produce tritium-filled glass tubes for use in self-luminous
emergency exit signs.
As a result of the Nuclear Safety and
Control Act coming into effect in 2000, SRB was issued a
Class 1B nuclear substance processing facility operating
licence for the same activities it had conducted in the
1990s.
This licensing action was accompanied by
an environmental assessment that concluded the resulting
dose to workers and members of the public would be minor on
the environment and the health of Canadian citizens would
be protected.
However, the report identified the
requirement for an environmental monitoring program.
In 2005 SRB was issued a one-year licence
with restricted conditions due to SRB's failure to control
releases of tritium that resulted in groundwater
contamination.
In 2006 SRB applied for the renewal of its
operating licence, however the Commission was not satisfied
that SRB could continue to operate due to its tritium
releases and resultant groundwater contamination.
As such, SRB was not permitted to process
tritium.
From 2006 to 2008 SRB undertook several steps to
mitigate its tritium emissions and protect the groundwater
39 resource.
These mitigation measures, including the
replacement of oil pumps with pumps that did not use oil,
changes to tritium handling practices, and retrofitting the
filling rigs.
In 2007 this SRB licence was amended to
allow SRB to assemble signs using light sources
manufactured elsewhere.
At that time, the Commission
requested CNSC staff to initiate research studies on
tritium releases in Canada.
In response, the CNSC Staff undertook
several research projects under the banner of the tritium
studies project.
In 2008 SRB applied to the CNSC to amend
its licence to resume processing of Tritium for a period of
two years.
The Commission concluded that SRB had made
major improvements to its qualifications and performance in
the area of environmental protection.
Consequently, SRB was issued a two-year
nuclear substance process facility operating licence.
Between 2008 and 2010 CNSC Staff conducted tritium studies
under the banner of the tritium studies project.
The
project resulted in seven CNSC publications that are now
available on the CNSC website.
In 2010 SRB's operating licence was
40 renewed for a period of five years.
At the time of
renewal, CNSC staff provided additional information on
groundwater detailing the trend in tritium concentrations
in residential wells, CNSC Staff's assessment of the
movement of tritium in groundwater, and CNSC Staff's
conclusions
The graph on this slide shows the amount
of tritium that was released from SRB since the year 2000.
Releases in 2000 were near 18,000 terabecquerels per year
and decreased to less than 100 TBq per year when operations
ceased after CNSC regulatory action.
Improvements to facility design and
operations, together with an improved safety culture at
SRB, have kept releases below 100 TBq after operations
recommenced in 2008.
The blue insert is an expanded view that
better illustrates the low releases since 2008 and during
the current licensing period.
Tritium releases from the SRB facility to
the environment occur by way of stack releases.
not released directly to groundwater.
Tritium is
Tritium, because of
its association with water, is deposited on the ground
surface as moisture or rainfall.
Tritium then migrates
through the soil to the underlying groundwater table.
While releases to the atmosphere and
41 deposition on the ground surface can occur relatively
quickly, the migration of tritium from the ground surface
to the underlying groundwater takes approximately five to
eight years near the SRB facility.
This is in important distinction for
impacts to groundwater.
And this understanding of tritium
behaviour in the environment is the basis for restriction
on the SRB facility to stop operations during rainfall
events.
This figure provides the most recent
average annual groundwater monitoring data near the SRB
facility.
As expected, the highest tritium levels in
groundwater occur adjacent to the stack at SRB.
The groundwater flow direction is towards
Muskrat River.
However, groundwater flows very slowly in
this area, on the area of a few metres per year.
And
Muskrat River is approximately 400 m from the SRB facility.
The concentration pattern observed in this
slide is reflective of the aerial deposition pattern and
not the migration of a plume.
That means the values in
Muskrat River are not expected to increase from what is
observed today.
The river is protected and will remain
protected.
Tritium values in wells located in the
nearby residential area are near or below 200 Bq/L.
These
42 values are well below the provincial drinking water
standard of 7,000 Bq/L.
Moreover, these residences are
connected to the municipal water supply whose intake is
from the Ottawa River.
Monitoring data from the Ottawa
River are near the detectable limit of tritium of 5 Bq/L.
During SRB's last licence renewal
application in 2010 the Commission, as well as CNSC Staff,
were concerned about the apparent increasing trend of
tritium concentrations at monitoring well MW 6-10 under the
SRB stacks.
CNSC Staff were paying serious attention
to the matter and conducted groundwater modelling to gain
some knowledge as to whether the increasing trend would
continue.
And, if yes, for how long?
CNSC Staff also wanted to independently
verify the licensee's conclusion that the high tritium
concentrations in the soil were due to historic practice
and not related to current emissions.
CNSC Staff use modelling to help provide
the Commission with information for the regulatory decision
making.
The modelling results for tritium
concentrations at groundwater monitoring wells at this SRB
site predict the concentration trends and is based on
average hydrological and hydro geological parameters using
43 soil moisture data obtained in 2006.
The modelling gave Staff confidence that
at the time of the work in 2010 the tritium concentrations
were caused by high tritium concentrations in the soil due
to previous years' inventory, and that tritium
concentrations in this monitoring well would continue to
increase for a short period of time and then they would
eventually start to decline.
In the plot, additional measured data from
2010 to 2014 were added to the 2010 prediction.
From this
plot, one can see that although there is high variation in
the measured data, they do support the predicted trend to
provide further evidence to confirm CNSC's understanding of
the behaviour of tritium in the groundwater.
The data plotted on these graphs provide
additional evidence that groundwater conditions near the
SRB facility continue to recover after relatively high
concentrations that were observed previously at this
facility.
The figure on the left is a monitoring
well that is located adjacent to the SRB facility.
well is for monitoring.
This
It is capped and locked, and it is
not accessible for drinking.
Concentrations in this monitoring well
exceeded 100,000 becquerels per litre in 2007, but have
44 since declined to below the provincial drinking water
standard of 7,000 Becquerels per litre.
The figure on the right is a well located
at a business located adjacent to SRB.
The tritium
concentrations exhibited an increasing trend, followed by a
long and steady declining trend.
This observation is also
reflective of high concentrations of tritium in the soil
profile when emissions were high, followed by a period of
recovery or improvement now that SRB has greatly reduced
its releases to air.
In January 2007, the Commission directed
CNSC staff to initiate research studies on tritium releases
in Canada and to study and evaluate tritium processing
facilities, exercising the best practices around the globe.
In response, the CNSC has undertaken several research
projects under the banner of the tritium studies project.
The purpose of this research was to
enhance the information used in the regulatory oversight of
tritium processing and tritium releases in Canada.
The research included a review of tritium
in drinking water, the environmental fate of tritium in the
atmosphere, soil and in vegetation and garden produce, and
the studies included the environment around the SRB
facility here in Pembroke.
Tritium from nuclear facilities is
45 released as HT, a gas, or HTO, which is tritiated water.
The tritiated water is deposited on soil, a portion of
which is converted to organically-bound tritium, or OBT.
The models used to predict tritium
concentrations in local produce tend to over-predict total
tritiated water, but have under-predicted the proportion of
organically-bound tritium.
This has been taken into
account in the calculation of public dose resulting from
the release of tritium by using directly locally-measured
HTO and OBT in public dose calculations.
It was determined that the contribution of
tritium to the public dose in Pembroke as well as near
other nuclear facilities in Canada is very low.
The CNSC staff has also studied the health
consequences of tritium near nuclear facilities in Canada.
The results of laboratory studies demonstrate that
detrimental health effects could only occur if doses were
much higher, a million times higher, than doses the public
would receive from Canada's nuclear facilities.
Epidemiological studies examined 42,000
Canadian nuclear workers and found no evidence of health
risk from tritium exposure.
These same studies have shown that public
doses resulting from Ontario nuclear facilities are 100 to
1,000 times lower than typical natural background
46 radiation.
And finally, this work also demonstrated
that there was no evidence of childhood leukemia clusters
near nuclear facilities in Canada.
In summary, the environment and the health
of Canadians is protected through the CNSC's regulatory
oversight from facilities that release tritium.
I would now like to focus this
presentation on today's application for the renewal of the
SRB operating licence.
Licensing considerations were based on
CNSC staff's review of the licence application and the
information submitted to support the application.
In
addition, CNSC staff assessed SRB's past performance and
its compliance with the regulatory requirements of 13
safety and control areas and other matters of regulatory
interest.
A summary of this assessment is provided
in the following slides.
In general, SRB's compliance record over
the past five years has demonstrated a commitment to safety
and to transparency.
CNSC staff are recommending the removal of
the safeguards licence condition from SRB's new licence
because the existing licence condition is redundant with
47 Section 12(1)(1) of the General Nuclear Safety and Control
Regulations, which states that:
"Every licensee shall take all
necessary measures to facilitate
Canada's compliance with any
applicable safeguards agreement."
For licensees with small inventories of
low significant materials, the General Nuclear Safety and
Control Regulations alone is considered sufficient.
For SRB, this regulatory requirement
applies to a quantity of depleted uranium that is used in
SRB's process.
All shipments of tritium to international
destinations or receipt of tritium for an international -from an international destination must be authorized by the
CNSC through the issuance of separate -- of a separate
licence under the CNSC's nuclear non-proliferation
import-export regulations.
The proposed removal of the safeguards
licence condition will not alter in any way the
non-proliferation obligations on SRB in regards to tritium,
which are derived from the CNSC regulations.
Lastly, I wish to take this opportunity to
clarify the status of tritium with respect to IAEA
safeguards agreements.
48 As per the Treaty on the Non-Proliferation
of Nuclear Weapons and the Canada IAEA safeguards
agreement, IAEA safeguards cover uranium, thorium and
plutonium-239, which are materials which could be directly
or indirectly used to make a nuclear weapon.
While tritium can increase the yield of a
nuclear explosion and is thus covered by the CNSC's nuclear
non-proliferation import-export regulations, it cannot
generate a nuclear explosion on its own and so is not under
IAEA safeguards.
I would like to make a correction with
regards to CNSC staff request for delegation of authority.
In CMD 15-H5, we have requested that the Commission accept
the delegation of authority to CNSC staff as outlined in
the proposed Licence Condition Handbook.
Staff are rescinding this request, as
there are no hold points in the proposed licence, and any
changes to the facility outside of the licensing basis
would require Commission approval.
The Licence Condition Handbook will be
modified to reflect this change before it would be issued
to the SRB should the Commission decide to renew the
licence.
SRB is currently regulated by the CNSC
with a Class 1B nuclear substance processing facility
49 operating licence that was issued pursuant to the Nuclear
Safety and Control Act.
In general, after the Commission
grants a licence, the role of CNSC staff is to provide the
regulatory oversight in order to ensure that SRB is
operating its facility in a safe manner in compliance with
the Nuclear Safety and Control Act, its Regulations, SRB's
operating licence that authorizes its activities and SRB's
programs that are used to meet the regulatory requirements.
To ensure the facility operates safely,
CNSC staff apply a risk-informed approach to the compliance
oversight of the SRB facility.
The level of risk at this facility is
considered in the development of compliance verification
program and the frequency at which safety and control areas
are inspected.
As part of the compliance oversight, CNSC
staff perform inspections, desktop reviews of SRB's
programs and procedures, event reviews and reviews of
annual compliance monitoring and operational performance
report.
Performance at each safety and control
area is continually assessed by CNSC staff and reported
annually in CNSC staff annual reports to the Commission.
CNSC staff ensure that SRB staff are
qualified to perform their work, that the facility and
50 equipment is maintained and updated if necessary to respond
to lessons learned from operating experience.
CNSC staff track all identified
non-compliance to resolution.
Any risk significant issues
are brought in front of the Commission as per the event
initial report process.
SRB is responsible for ensuring the safe
operation of its facility, whereas CNSC staff independently
verify SRB's performance.
CNSC staff conducted several site visits
with SRB during this licensing period.
Typically, CNSC
staff conduct these visits to observe the conditions at the
facility, to introduce updated standards or clarify
expectations with licence's management and staff.
For example, in 2014, staff visited SRB to
discuss topics such as the 2015 relicensing activities,
implementation of updated personal training regulatory
requirements and Canadian Standards Association management
system requirements for nuclear facilities.
In addition, using a risk reformed
regulatory approach, staff performed a minimum of one
inspection per year at SRB.
Because of the low level of
complexity of the SRB facility, it is possible to inspect
several safety and control areas during a single
inspection.
51 The compliance verification activities,
therefore, include standard checks of SRB's program in all
13 safety and control areas.
Licensees are required to submit a report
within 20 days of a reportable event.
CNSC staff perform
desktop reviews of these reports and ensure adequate
corrective measures have been implemented to prevent the
recurrence of a similar event.
SRB had no reportable events during this
licensing period.
Enforcement actions are a part of the
normal ongoing compliance processes used by CNSC staff.
The enforcement tools available to CNSC staff include
orders, directives, action notices and administrative
monetary penalties.
During the current licensing period, staff
issued 12 action notices to SRB.
There are no open
enforcement actions with SRB at this time.
All were closed
to the satisfaction of CNSC staff.
To date, SRB has addressed all CNSC staff
requests requiring no escalation of enforcement actions
during the licensing period.
Finding of these inspections identified
areas for improvement as opposed to regulatory
non-compliances.
None of the identified inspection
52 findings during the licensing period pose an immediate or
unreasonable risk to the health and safety of persons or
the environment.
Rather, the findings were required to
address -- to be addressed for better alignment to SRB's
own programs and for continual improvement.
Performance in all safety and control
areas has remained satisfactory to fully satisfactory
during the current licensing period.
SRB staff have the
expertise and qualifications to safely carry on the
activities authorized by the licence.
No worker or member of the public received
a dose in excess of the regulatory dose limits, and all
radiological releases were well below regulatory limits.
An environmental assessment under the
Nuclear Safety and Control Act and its Regulations was
conducted for this application.
CNSC staff conclude that
SRB will make adequate provision for the protection of the
environment.
Only one lost-time incident occurred
during the licensing period.
SRB's programs were
implemented and maintained effectively in accordance with
its own operational requirements and licence requirements.
This slide provides a summary of SRB's
ratings over the current five-year licensing period for 13
safety and control areas.
Overall, the safety and control
53 areas range from satisfactory to fully satisfactory.
The safety and control area convention on
health and safety was rated fully satisfactory in 2013 and
2014 as a result of its consistent record of worker
protection.
In 2014, CNSC staff rated SRB's fitness
for service program as fully satisfactory as a result of
several improvements to its manufacturing process,
equipment and revision of its maintenance program in 2014.
These improvements proactively
incorporated best industry practice.
SRB has implemented and maintained an
effective radiation protection program as required by the
radiation protection regulations.
All workers at SRB have
been designated as nuclear energy workers in accordance
with the radiation protection regulations.
Radiation exposures are monitored to
ensure compliance with the CNSC's regulatory dose limits
and with keeping doses as low as reasonably achievable.
Throughout the current licensing period,
no worker's radiation exposures reported by SRB exceeded
the CNSC regulatory dose limits.
The maximum effective
dose by a worker in the current licensing period was 1.93
millisieverts, or approximately four percent of the
regulatory limit of 50 millisieverts in a one-year
54 dosimetry period.
The yearly variation of SRB staff's
radiation exposure is directly correlated with three
primary factors; the level of tritium processing, the types
of light sources being manufactured and the results of
ALARA-driven improvements to manufacturing processes,
equipment and programs.
CNSC staff are satisfied that doses to
workers are being controlled well below the regulatory
limits and are maintained as low as reasonably achievable.
Public dose resulting from the SRB
facility is based on environmental monitoring results.
The
maximum dose to a member of the public as a result of the
emissions from SRB over the term of the licence have been
less than 0.007 millisieverts.
This is 0.7 percent of the
annual public dose limit.
The increase in calculated maximum annual
effective dose to a member of the public from 0.004
millisieverts to 0.007 millisieverts observed in 2013 and
'13 is attributed to approximately threefold increase in
tritium processing during the same period, from
approximately 10,000 terabecquerels in 2012 to 30,000
becquerels in 2013.
Based on the review of the dose data, CNSC
staff are satisfied that SRB is adequately controlling
55 radiation doses to members of the public to levels well
below regulatory limits.
A key performance measure of the
conventional health and safety is the number of lost time
injuries that occur per year.
And a lost time injury is an
injury that takes place at work and results in the worker
being unable to work -- to return to work, carry out their
duties for a period of time.
During the licensing period, SRB continues
to demonstrate its ability to keep workers safe from
occupational injuries while tritium processing increased
and, as a result, SRB increased its staff from 15 to 43
employees to meet their production demands.
Only a single lost time injury occurred
during the current licensing term as a result of an injury
that occurred during the machining process in a zone where
no tritium is handled or processed.
As seen in this table, SRB's releases to
the atmosphere continue to be effectively controlled and
are consistently well below the release limits prescribed
in its operating licence.
The release limits are based on
environmental protection and ensure sustainability use
of -- sustainable use of groundwater resources as well as
consideration of public dose implications.
The release limits for SRB are much lower
56 than would be required to protect the public so the
groundwater as a resource can also be protected.
There were no licence limit exceedances
during the current licensing period.
However, during the
period of October 28th to November 4th, 2014, there was a
gaseous tritium action level exceedance of the weekly
action level for tritium.
The release represented 3.7 percent of the
annual release limit for total tritium.
SRB conducted an investigation into this
exceedance to identify the contributing cause and root
cause.
SRB's investigation concluded that the higher
tritium emissions were related to a leak in a gaseous
tritium light source and a second leak in a manifold gauge.
CNSC staff reviewed SRB's investigation
report and corrective actions, and found both to be
acceptable.
SRB continues to effectively control
tritium releases to air from the facility and are well
below licence limits.
The monitoring data for releases to the
sewer system from 2010 through 2014 are shown in this
table.
The data shows that liquid effluent from the
facility continues to be effectively controlled and that
tritium releases are well below the licence limit.
57 The IAEA has published IAEA Tecdoc-000
titled "Clearance of Materials Resulting from the Use of
Radionuclides in Medicine, Industry and Research".
This document provides a method for
calculating permissible releases to sewer systems that
would ensure that municipal workers are protected if all
the tritium remains in the sewage sludge and if all the
tritium is released to a small river system.
The CNSC has selected 20 percent of the
level that is determined from this international approach
as the licence limit, and SRB has been releasing tritium at
much lower values relative to the licence limit.
SRB continues to effectively control both
releases to air and releases to the sewer system, and all
releases remain well below licence limits.
SRB has a very good safety record.
There
are currently no safety concerns and, from CNSC staff
perspective, no impediments to renew the operating licence.
Nevertheless, CNSC staff have regulatory
focus areas which stem from Commission's direction, from
operational experience and/or new research findings.
The
two main focus areas for this licence renewal are, first,
the implementation of updated standards in Regulatory
Documents and, second, environmental monitoring.
These are described in more detail in the
58 following slides.
SRB is working in these areas for
continuous safety improvement, which is an integral part of
the CNSC regulatory framework.
This table shows eight updated CSA
standards and Regulatory Documents that are proposed for
inclusion in the Licence Condition Handbook.
The
implementation dates are listed on this slide.
SRB submitted to CNSC staff revised
training program in January 2015 that meets the
requirements of the personal training Regulatory Document
2.2.2.
CNSC staff will continue to monitor the
implementation and effectiveness of this updated program.
In addition, CNSC staff will continue to
update the Commission on the progress of these continuing
improvement activities by the annual regulatory oversight
report on uranium in nuclear processing facilities.
During the licensing period, tritium
processing at SRB ranged from 6,644 terabecquerels in 2010
to a maximum of 30,543 terabecquerels in 2013.
However,
releases of tritium to air relative to the amount of
tritium processed reached their lowest point in 2014 after
three consecutive annual reductions.
CNSC staff attribute this decrease in
relative emissions to the tritium reduction initiatives
59 undertaken by SRB during the licensing period.
Despite the production increase, SRB's
environmental limits found in the proposed Licence
Condition Handbook will remain the same as in the current
licence.
CNSC staff have verified through their
compliance activities that SRB has adequate operational
controls to provide assurance that the release limits
stipulated in the operation licence would not be exceeded.
SRB monitors 46 groundwater wells around
the SRB facility.
Since renewal of the licence in 2010,
SRB has conducted a groundwater study which confirmed that
the residential wells with the highest tritium
concentration of 226 becquerels per litre in 2013 and the
Muskrat River with tritium concentrations for the last two
years in the range of three to 22 becquerels per litre are
not at risk of exceeding the Ontario drinking water quality
standard of 7,000 becquerels per litre.
The highest tritium concentration in a
potential drinking water well was found in business well
B2, averaging 1,238 becquerels per litre in 2014.
SRB continues to provide bottled drinking
water to the business, even though the tritium
concentrations are well below the Ontario drinking water
standard.
60 CNSC staff independently -- independent
analysis of SRB's groundwater monitoring results are
further discussed in the environmental assessment
information report found in Addendum E of CMD 15-H5.
Overall, CNSC staff conclude that the
tritium inventory in the groundwater system around the
facility has been stabilizing and improving as expected.
The Canadian Nuclear Safety Commission
conducts environmental assessments under the Nuclear Safety
and Control Act for all projects in accordance with its
mandate to ensure the protection of the environment and the
health of people.
As found in Appendix E of CMD 15-H5,
CNSC staff prepared an information report based on the
environmental assessment review completed for the licence
renewal application submitted by SRB.
As a result of the environmental
assessment review, CNSC staff conclude that SRB has and
will continue to make adequate provision for the protection
of the environment and the health and safety of persons.
CNSC staff launched an environmental
monitoring program for SRB.
CNSC staff independently
monitored results to confirm that the public and the
environment around the SRB are safe.
These results -- the
results of the independent environment monitoring program
are consistent with the results submitted by SRB,
61 confirming that the
licensee's environmental protection
program protects the health and safety of people and the
environment in the vicinity of the SRB facility and that
there are no health impacts.
These results are published
on CNSC's website and demonstrate continuous improvement
efforts of both SRB and the CNSC's ability to communicate
its regulatory oversight.
In 2013, as requested by the Commission,
CNSC staff measured the concentrations of tritium in sewage
sludge in various municipalities in Ontario, 11 in total.
This request was in response to concerns raised in 2011 by
members of the public during the Commission's meeting for
SRB's Annual Status Report on the safety performance of the
facility.
The tritium concentrations in sewage
sludge and liquid effluent were below the analytical
detection limit for all wastewater treatment plants sampled
except for those in Peterborough and in Pembroke.
Using the finding from Pembroke Wastewater
Treatment Plant, the doses of radiation from the measured
concentration of tritium in sewage sludge were calculated
for two representative persons: a worker in the wastewater
treatment plant involved in sewage sludge loading, and a
worker at a municipal landfill who was involved in applying
landfill cover to waste.
The estimated annual effective
62 doses were 10,000 to 5 million times below the regulatory
annual public dose limit of 1 milliSievert.
doses is known to cause health effects.
Well below
The dose from
tritium in sewage sludge also represents a small fraction
of the natural background radiation.
As a result, the
report concludes that there was no impact on public health
and supports the licence limit for SRB's releases to the
sewer as being very protective.
The CNSC ensures that all of its licence
decisions under the Nuclear Safety and Control Act uphold
the honour of the Crown and consider Aboriginal people's
potential or established Aboriginal and/or treaty rights
pursuant to section 35 of Constitution Act, 1982.
Aboriginal groups who previously expressed
interest in being kept informed of CNSC licence activities
occurring in their traditional territories were sent
letters in December of 2014 providing them with information
regarding the licence renewal application, the opportunity
to apply for participant funding, and details regarding the
Commission's public hearing.
Follow-up phone calls were
conducted to ensure that they had received the letters and
to answer any questions.
To date CNSC staff have not been
made aware of any concerns related to the licence renewal
from the identified First Nation and Métis groups.
At renewal in 2010, the Commission
63 exempted SRB from the Cost Recovery Fees Regulations.
The
exempt was temporary and conditional upon the payment of
the fees as per the schedule stipulated under licence
condition 16.1 of the current operating licence.
SRB
complied with the prepayment schedule stipulated in the
current licence.
The final payment and total cost
adjustments were paid September 25th, 2013.
SRB is now in
good standing with respect to Cost Recovery Fees
Regulations requirements.
As a financial guarantee instrument, SRB
proposes to continue to use a revised escrow agreement and
a revised security and access agreement providing CNSC
access to the funds.
SRB proposes to fund the increase of
$102,012.00 from the previous cost estimate of $550,476.00
by making six equal installments of $17,002.00 to the
escrow account over a three year period.
CNSC staff
conclude that SRB's financial guarantee meets the
applicable regulatory requirements under the Nuclear Safety
and Control Act.
SRB's Public Information and Disclosure
Program meets all requirements and intentions outlined in
the regulatory document 99.3, Public Information and
Disclosure.
SRB has taken several improvements to its
program, demonstrating a commitment to establish an
atmosphere of openness and transparency regarding the
64 health and safety of the public and the environment as it
relates to its licence activities.
The CNSC made funds available through its
Participant Fund Program to assist members of the public,
Aboriginal groups, and other stakeholders, providing
value-added information to the Commission through informed
and topic-specific interventions.
Based on recommendations
from a Funding Review Committee, the CNSC awarded a total
of $20,770 in participant funding to representatives who
are required to submit a written order intervention and
make an oral intervention at today's hearing.
The proposed licence includes standard
licence conditions that make reference to licensee
programs.
Compliance verification criteria, such as
specific CNSC regulatory documents and CSA standards, have
been incorporated into the Licence Conditions Handbook.
The proposed operating licence and associated Licence
Conditions Handbook reflects the continuous nature of
safety improvements for the Canadian nuclear substance
processing facilities.
This concludes my portion of the CNSC
staff presentation.
I will now pass the presentation back
to Dr. Newland.
MR. NEWLAND:
Thank you, Mr. Rinker.
Based on the assessment of SRB's safety
65 performance, CNSC staff conclude that as per section 24(4)
of the Nuclear Safety and Control Act, SRB is qualified to
carry on the activities authorized by the licence, and in
carrying out those activities SRB has made and will
continue to make adequate provision for the protection of
the environment, the health, and the safety of persons and
the maintenance of national security, and measures required
to implement international obligations to which Canada has
agreed.
Therefore, CNSC's staff recommend that the
Commission accept CNSC staff's assessment and conclusions
pursuant to section 24 of the Nuclear Safety and Control
Act, the Commission renews the nuclear substance processing
facility operating licence NSPFOL-13.00/2025 for a 10 year
period.
And pursuant to section 24 of the NSCA, the
Commission accepts the revised financial guarantee set out
in Part 2, section 1.3 of the Licence Conditions Handbook.
Thank you.
That completes the staff's
presentation.
THE PRESIDENT:
Thank you.
I think it's a
good time to take a 15 minute break and on return we will
start directly with the interventions.
--- Upon recessing at 10:32 a.m. /
Suspension à 10 h 32
Thank you.
66 --- Upon resuming at 10:52 a.m. /
Reprise à 10 h 52
THE PRESIDENT:
We are back, and we are
going to start with the intervention.
Before we start, I'd
like to remind everybody we allotted 10 minutes for the
oral presentation because we have read all the documents
and we would like to engage in discussion rather than, you
know, having a long speech.
So -- and we have a long, long
day, a lot of interveners, so please help us on this one.
So with that comment I'd like to start
with the presentation by the Lake Ontario Waterkeeper and
Ottawa Riverkeeper as outlined in CMD 15-H5.2.
I
understand that Ms. Pippa will make the presentation.
UNIDENTIFIED SPEAKER:
THE PRESIDENT:
Feinstein.
It's Feinstein.
Oh, sorry, Ms. Pippa
I am sorry about that.
The floor is yours.
CMD 15-H5.2
Lake Ontario Waterkeeper and Ottawa Riverkeeper
MS FEINSTEIN:
Binder and Commission Members.
Good morning, President
Thank you for the
opportunity to address you all today.
67 For the record my name is Pippa Feinstein
and I am representing Lake Ontario Waterkeeper and Ottawa
Riverkeeper.
Both organizations were founded in 2001 and
are members of the International Waterkeeper Alliance.
They both tirelessly advocate for local swimmable,
drinkable, and fishable water, and they seek to empower
people in order to stop pollution, protect human health,
and restore habitat.
They have significant expertise
concerning the development of public information sharing
programs and building meaningful industry stakeholder
relationships.
Over the course of the next 10 minutes I
would like to make two broad submissions to you all.
The
first is that the Commission should not renew SRB's licence
for a period longer than five years.
And the second is
that regardless of the length of any licence renewal, SRB's
Public Information Program should be improved.
We have
made several suggestions for how this could be done and we
request that the Commission include our recommendations as
conditions on SRB's licence.
On the first point, we submit that 10
years is simply too long to go without a public hearing for
the SRB facility.
If the Commission decides to renew the
facility's license, a five year term would be better for
SRB, the local community, and the environment.
This is
68 because:
1. more frequent hearings can increase SRB's
financial security; 2. more frequent hearings are necessary
because of SRB's rapid growth; 3. hearings every five years
are not an unreasonable burden on SRB, and 4. more regular
hearings could better assist the Commission to assess SRB's
impact on fish and fish habitat.
I will briefly discuss
the rationale for each of these in turn.
First, hearings every five years can
increase SRB's financial security.
This is because they
can help the facility comply with its licence conditions.
They can also help SRB maintain its social licence to
operate in Pembroke.
Hearings include avenues for more
meaningful public inclusion, which can improve the
relationship between the facility and local community,
which can have economic implications.
Hearings can also
include opportunities for SRB to receive diverse expert
information, perhaps more diverse than SRB might be able to
retain on its own, and these can also help SRB ensure that
its operations are as efficient and safe as possible.
Ultimately it's SRB's conduct and not hearings that
determine the financial security of the facility.
As long
as the facility complies with requisite licence conditions
and regulatory standards, hearings should not threaten its
ability to operate or its ability to enter into beneficial
contractual agreements.
In reality, hearings every five
69 years, not every 10 years, should help manage SRB's
economic insecurity.
Second, more frequent hearings are
necessary because of SRB's recent growth.
Over the last
licence period, as we heard from a CNSC presentation
earlier, SRB's tritium production has increased almost
fivefold.
SRB also expects that the amount of tritium
processed -- sorry, over the -- it's increased fivefold
over the last licence period.
SRB also expects the amount
of tritium processed at the facility to increase by an
additional 15 percent over the course of 2015 alone.
Emissions over the course of the previous licence term have
more than doubled and radioactive waste generated at the
site has also doubled.
Ten years of continued growth like
this without public hearings would not be in the public
interest.
If emissions increase by a factor of 5 to 8 and
production volumes increase twice as much, as has been the
trend so far, the facility could still arguably meet its
licence limits, and yet were this to happen the character
of the facility and its environmental impacts would say
change significantly.
Such growth should not be allowed to
occur without meaningful input from members of the public
who would be most impacted by these changes.
Third, hearings every five years would be
appropriate in the circumstances and not unreasonably
70 burden SRB.
The facility has a long history of
environmental non-compliance and associated contamination
of local groundwater.
As we have seen over the last
several years, regulatory vigilance is necessary in order
to ensure SRB mitigates its adverse environmental impacts.
As the Commission will hear from
submissions from other interveners later today, actual
groundwater contamination levels are persisting longer and
in greater concentrations than CNSC modelling had
predicted.
of doubt.
As such, SRB should not be afforded any benefit
Regulatory vigilance is required and more
regular hearings would be an important aspect of this
vigilance.
SRB argues that money saved through less
frequent hearings would help fund advances in tritium
emissions reductions or provide more funds for their safety
program or decommissioning fund.
However, we submit that
if SRB can't afford to adequately fund these initiatives,
it should simply not be permitted to operate.
It would be
unreasonable to sacrifice opportunities for meaningful
public participation in order to ensure that SRB fulfills
other licence conditions.
Fourth, more frequent hearings can be
helpful for the Commission's new authority of a fish
fisheries and species at risk.
This current licence
decision is the first for the SRB facility that is being
71 conducted under a new memorandum of understanding between
the Commission and the Department of Fisheries and Oceans.
The memorandum increases the scope of the Commission's
responsibilities in this regard; however, CNSC staff's
commission member documents have failed to include any
mention of fish, fish habitat or species at risk and
perhaps this is something that staff can address or clarify
once I finish this presentation.
More frequent public hearings could better
ensure that these matters receive adequate consideration in
the future and hopefully this could include the opportunity
for members of the public to retain third party experts to
examine this issue as well.
Having provided our arguments
in favour of more frequent licence renewal hearings, I will
now outline our recommendations for improving SRB's Public
Information Program.
Given SRB's environmental track record and
in during public concerns, its Public Information Program
should really be gold standard.
In order to better realize
this goal, we recommend the following improvements:
First,
that all environmental sampling results should be clear,
accessible, machine readable, and made public in real time;
2. that SRB should warn the public in advance of any
planned releases at the facility; 3. that more information
should be collected to inform SRB's internal reviews of its
72 Public Information Program, and 4. that SRB should continue
to update its website regularly.
All of these recommendations will
ultimately help SRB better meet the purposes of its Public
Information Program and these are articulated in the
Commission's Public Information and Disclosure guideline,
Regulatory Document 99.3.
Perhaps most importantly, the
guideline requires that SRB's Public Information Program be
proportional with the public's perception of risk and their
level of interest in the facility.
Since the public's
concern and interest in the facility is significant, SRB's
program should reflect this fact.
Our first recommendation is that all
monitoring results should be reported clearly, in real
time, and as machine-readable data.
Sampling results
should be posted to the SRB website within five days of
being received.
Once this data is posted to the SRB
website, it should remain posted indefinitely so that it
can be compared with subsequent sampling results.
This
requirement is not too onerous, as SRB would merely have to
post test results to the website the same week as they are
received.
This would also be consistent with 2.1 --
section 2.1 of the Commission's guideline which requires
the timely communication of information.
73 SRB's environmental sampling results
should also be made in 100 percent machine- readable
formats.
This could be as simple as changing these
documents from PDFs, as they currently are, to formats such
as RDF or XML.
The software required to do this is
relatively inexpensive and easy to navigate, but providing
sampling data in these machine-readable formats can be
extremely useful to the public, SRB, and the Commission.
This is because these formats basically allow data sets to
be more portable and extractable, allowing the values to be
input into other analytical software which can help
identify trends and data over time.
It is also important that the data be made
more accessible to the public in other ways.
For example,
every chart containing sampling data should clearly
indicate the relevant action levels and release limits on
that same chart.
Doing so would allow a layperson to
glance over the values in a particular data set and
immediately determine whether SRB is, in fact, complying
with the relevant limits.
This isn't always done in SRB's
annual compliance reports.
Our second general recommendation for
improvement is that the public should be warned in advance
of any planned effluent release event at the facility.
SRB's Public Information Program and Public Disclosure
74 Protocol are silent on this issue, so they should be
changed in order to require SRB to issue a notice on their
website at least 24 hours before a planned release at the
facility.
The notice should state when the release is
scheduled to occur, the amount of tritium or other
substances that will be released, and the purpose for the
release.
Third, more information should be
collected to inform routine evaluations of the efficacy of
SRB's Public Information Program.
The Commission
guidelines require SRB to periodically revise and improve
its program and SRB does have a Public Information
Committee that reviews the program quarterly; however, it
seems that these reviews may be based on little evidence.
I've got one more paragraph.
So we know that SRB maintains regular
records concerning discussions with local elected
officials, meetings with local special interest groups,
presentations before Pembroke City Council, general public
meetings, and other public presentations.
Perhaps SRB
staff can clarify whether records of those types of events
are consulted by the committee in their quarterly reviews.
Regardless, SRB should amend their program to explicitly
require the committee to consider these types of records.
75 And our final recommendation is that the
SRB website should be updated with information about public
outreach activities.
Currently the website has not been
updated to include Pembroke City Council presentations
between 2010 and 2013, or any public presentations since
2011.
As SRB documents and retains records of these public
presentations, it shouldn't be too difficult to update its
web page and ensure that these significant lapses don't
occur in the future.
So, that concludes my oral presentation.
I look forward to questions and discussion.
THE PRESIDENT:
Questions.
Thank you.
Thank you.
Mr. Tolgyesi.
MEMBER TOLGYESI:
If SRB's processing --
process tritium is about -- increased from 6,643
terabecquerels to over 28,000 terabecquerels, according to
the Licence -- Licence Handbook on page 9, licence
condition is that authorized possession up to limit of
6,000 terabecquerels of tritium in any form
[indiscernible].
Considering that -- considering this
6,000 terabecquerels limit, how far the volume of processed
tritium may grow?
You know, you increase from 6,600 to 28–
, and licensing limit is 6,000 terabecquerels possessed any
time, how far you could go?
don't know,
32,000 only?
You could go to 50,000 or, I
76 MR. LEVESQUE:
record.
Stephane Levesque for the
Thank you for the question.
The 6,000 obviously
refers to, as you know, a possession limit and has in no
way any affiliation with what we're processing.
no limit on how much we process at the facility.
There is
The limit
that we have is to ensure that we meet obviously our -- our
release limits and the possession limits of our licence,
but they're not affiliated at all with how much is
processed at the facility.
MEMBER TOLGYESI:
So you could grow your
processed tritium, your production, in a sense, up to it's
no limit there?
It is -- I understand that right?
MR. LEVESQUE:
record.
There -- again, there's no limit on how much we
can process in our licence.
So, yes, you could increase
tritium considerably as long as you stay within all your
other limits, the possession limit and your release limits.
MEMBER TOLGYESI:
Staff, do you have any
comments?
MR. RINKER:
Mike Rinker for the record.
So I think maybe what your question was getting at is how
much could they physically process, so is there a maximum
for which the plant could feasibly process in a year,
what -- what would be their operational maximum rather than
77 a regulatory limit.
So, I think SRB could -- could best
answer that question.
In terms of how they're regulated in terms
of how much they can process, there's two metrics.
One is
for the case of worker protection or in the case of
accidents or malfunctions or -- you know, or beyond design
based events.
We want to make sure there is a regulated
amount that can be in the facility at any one time.
In addition, regardless of how efficient
they become at processing, there's a maximum of which we
would want to see that gets released to the environment, so
we have set very tight limits.
So they could increase the
amount that they process annually without ever holding on
more than 6,000 terabecquerels as long as they are held
very tightly in terms of what they would release to the
environment.
So, they have to work within those bounds.
MEMBER TOLGYESI:
So as long as the
emissions are not reaching, I'm sorry, I tried to find your
limit, it was 448 -becquerels, terabecquerels, you could -as long as you don't reach that limit, you could increase
your production as far as you wish?
MR. LEVESQUE:
record.
Yes, right now we're at -- within the -- at the
licence period we were releasing at less than 18 percent of
our -- of our release limit.
And not to say that we would
78 increase production at that limited amount, you've got to
realize that the production increases that we have made
have been in steps.
We -- obviously it would be associated
with hiring new staff, commissioning possibly equipment
that would require obviously CNSC input.
simple as just increasing production.
So, it's not as
It -- there's a lot
of things that would have to happen.
To try and answer your question, with the
current equipment that we have and by adding a few staff
members, we -- we can see that we could increase the
production maybe by another 50 percent reasonably.
If we
were to go above that 50 percent, there would need to be
some significant steps that have to take place that may
require consultation with CNSC staff regarding
commissioning and new equipment and so on and so forth
because that's not part of our Safety Analysis Report as
they are right now.
So, you know, with the existing
equipment, adding a few staff members, in steps we could
increase it by another 50 percent if that's kind of what
your question is.
MEMBER TOLGYESI:
Yes.
It's unusual that
a licence is given in function of -- of emissions, not in
function of volume processed.
Usually when you look there
is a volume processed which is governing what you could do.
79 MR. RINKER:
That's a good question and it's one that we've -- we've
considered over the licensing review.
What we've looked
at, however, though, is SRB has maintained their ability to
reduce emissions relative to production increase.
So, the
amount -- if we regulate it in terms of production
increase, we would have to determine what does that mean in
terms of health effects.
So the decision that we made in
proposing a licence as we did was to regulate worker safety
in terms of possession limit and to regulate environmental
protection in terms of release limits, and that would allow
SRB the flexibility -- provided they're within their
licensing -- licensing bases, using the same equipment and
the same process and so on, to have the flexibility to
increase efficiencies, improve on emissions and perhaps
increase the amount of tritium they could process, provided
that their environmental protection and worker health and
safety remains the same.
THE PRESIDENT:
Okay.
Ms. Velshi.
MEMBER VELSHI:
Thank you, Mr. President.
The question is for SRBT.
The intervener
makes some fairly specific recommendations around
additional disclosure on your environmental results.
And I
know in your opening statement you -- you had said you are
80 already going to be addressing some of these, but perhaps
you can turn to page 13 of the intervention and comment on
the four specific recommendations around additional
disclosure and what your thoughts are on those.
So, over
to you.
MR. LEVESQUE:
record.
We feel that right now, I would say approximately
90 percent of our monitoring results are reported clearly
in both our Annual Compliance Report, which is posted on
the website and separately on our website in an area in -regarding our emissions reporting and environmental
monitoring.
Of all the surveys that we've done of the
public, conversations that we've had -- just at the local
community, mind you -- we've never had a comment or
anything of the sort of an individual that had an issue
with the way that we were reporting the information on our
website.
The only comment I've received prior to this
intervention was some people weren't really computer-savvy,
wanted a hard copy of the information, which we've done.
I personally don't have any experience
with machine-readable data.
I've been doing some research
since I've seen this intervention.
I know that we had a
lot of members of the public that wanted us to save the
information, have it in PDF format, because we used to do
81 it in Excel in the raw form that people could extract the
data.
But people didn't always have the up-to-date latest
software, so it created a problem for them.
So we found
that since we've done it in PDF in one of the older
formats, we didn't really have an issue.
There's a number of members of the public
as part of these interventions in terms of Dr. Hendrickson
and Ms O'Grady that have asked us for information
supplementary to what's on our website, and we've always
provided it to them in whatever format they wanted.
They've asked us to give it in Excel or in Word so they
could manipulate the data, and we've always done that.
So we're open to taking those requests on
the one-on-one basis and changing it in whatever format we
can.
And in the meantime, we can investigate what this
machine-readable data is.
MEMBER VELSHI:
recommendations.
So there are four
But that first one that you have been
addressing, it also talks about in real time as opposed to
waiting for the Annual Compliance Report.
So right now do
you update the information on your website fairly soon
after the results are in?
MR. LEVESQUE:
record.
We also do quarterly reports to the CNSC,
82 and as soon as a quarterly report is completed and compiled
and sent to CNSC staff, we post it within a few days.
I
think it's always within actually five days of compiling
the report.
On a monthly basis, we also post
groundwater monitoring data a few days after we receive the
data from our third party.
So on those we do right away.
Some of the other data, like the 10 per
cent I was talking about, that only gets found once a year
in our Annual Compliance Report.
But again, if somebody
wanted it more frequently we would put it in.
That's
something we're looking at reviewing, to put more data on a
quarterly basis with the report.
MEMBER VELSHI:
Thank you.
And what about
the second recommendation, about advance warning of any
unusual emissions?
MR. LEVESQUE:
record.
People have to really understand maybe our
facility and the way it operates a little more.
We don't typically have planned releases.
The releases happen with each process.
And there's
releases made continuously throughout the day as we process
tritium, small releases.
We've had one, I can say, planned release
83 over this and the previous licence period of liquid
effluent, because we wanted to look at the effect into the
sewer system.
So definitely, if we were to make in the
future another planned release we would definitely put it
on our website.
And that's one of the inputs we'll put in
our Public Information Program Committee.
MEMBER VELSHI:
And I believe it was that
specific incident that you talked about that the public
should get a heads-up on, that that's going to be
happening.
Over to you, if you have any comments.
MS FEINSTEIN:
I'm just wondering if I can
respond to things maybe when you're finished, Member
Velshi.
Thank you.
MEMBER VELSHI:
And the third one was
around the efficacy of your Public Information Program.
And maybe you can spend a few minutes and talk about how do
you measure on how well that program is working.
MR. LEVESQUE:
record.
As a prelude to starting to talk about
that, I really have to say that before this licence renewal
process, over the entire licence period we have only
84 received two enquiries from members of the public.
So you
can understand that when we look at assessing how well our
Public Information Program works and we only have received
two enquiries, that doesn't give us a lot of set data to do
that.
While we strive to do better, obviously,
based on the number of interventions that we had mostly
from people outside the community, it's going to allow us
to revise the Public Information Program and use that
input.
Now we have a lot more data that people outside the
community have concerns and we can address those.
But that's our intent is to review the
data that we gather over that quarter with any information
that we have and adjust our public information.
I think the program that we have is good.
It was deemed fully satisfactory by CNSC staff and had a
target audience that was very specific, obviously, with
people located in our area.
But now we understand from the
intervenors that outside of the Pembroke and community that
we have to include that as part of our Public Information
Program.
MEMBER VELSHI:
Does your Public
Information Program consider doing opinion surveys of any
kind?
85 MR. LEVESQUE:
record.
Yes, and we actually performed one very
recently of, again, the focus group of our Public
Information Program, which is the individuals that live
within 500 metres of the facility.
We send surveys to
these individuals and ask them if they were happy with the
program, have they heard of our facility, did they want to
get data more often, less often, in what format.
So yes, we've done that and we'll continue
to do that.
And if we're given the contact information for
all the intervenors here today, we'll include them in our
next one as well.
MEMBER VELSHI:
Thank you.
Ms Feinstein, over to you.
MS FEINSTEIN:
Thank you.
Pippa Feinstein
for the record.
There are three broad points that I'd like
to make, if possible.
The first concerns the issue of formatting
that Mr. Levesque raised.
I would propose that if PDF is
helpful for some members of the public, that this shouldn't
stop information from being released in both PDF formats
and potentially machine-readable data.
So the fact that
PDFs have been useful to some people in the past shouldn't
86 preclude the ability for SRB to also provide
machine-readable formats.
The second issue, regarding real-time
release of data:
I understand that much environmental
monitoring happens on a monthly basis, and to my knowledge
monthly sampling data is not posted on the website.
So
that's more the type of real-time data that I'm asking
about in the circumstance.
While the Annual Compliance
Reports are useful for seeing sort of yearly, overall data
sets, having them in real time allows members of the public
to see what changes are like month by month, to understand
what's happening at the facility at the time.
The third broad issue is something that
keeps coming up in the Commission Member Documents by SRB
as well as their presentations today, which is that because
only two members of the public had concerns over the
licence period, that public concern is quite low.
And I think this sort of comes back to the
point that I was trying to make in my written submissions
in that public hearings are the main place where members of
the public can vent their concerns and make suggestions and
really engage with what's happening at the facility and the
types of regulations that they feel are appropriate or
helpful.
And what we see when we do look at these
87 public hearings is that the public has been very active.
There have been up to 60 or 70 interventions in public
hearings.
Interventions from the community tend to be very
detailed and outline a series of serious concerns to the
public.
So when we talk about the public
engagement with the facility or their concerns with the
facility, it's important to remember how hearings are an
important venue for the public to express themselves.
And
this is another argument for why public hearings are so
important.
In addition, it's important to remind
ourselves that the Public Information Program is really
designed in such a way that it facilitates one-way
communication, and that's really the communication of
information from the facility to the public.
But there are
no mechanisms within the Public Information Program that
allow for or that require the considerations of concerns
that are brought forward or that require SRB to act on the
concerns that members of the public may raise.
So in that way it's really exclusively
hearings that allow for that two-way communication that can
be so important.
Thank you.
MR. LEVESQUE:
88 record.
I assure you, as president and part-owner
of the company, that hearings aren't what makes SRB
Technologies provide the public information.
I think
that -- especially increasing in this licence term and the
one before that, the two-year licence -- we've always been
very open with the public, always given them all the
information that they requested, and been open to requests
for reviewing our operations in any way.
I think that's testified in some of the
things that we did.
Despite having only logged two
enquiries over that licence period, that we've mailed out
10,000 pamphlets to members of the public.
We've done
door-to-door activities and the individuals that we've
spoken to that are in the local community.
We wrote to the
Aboriginal groups, to a number of stakeholders.
We've had
little to no concern.
But despite that, we're open throughout
any licence, whether it was a ten-year or five-year
licence, to answering the concerns of the public
regardless.
THE PRESIDENT:
Monsieur Harvey.
MEMBER HARVEY:
Merci, Monsieur le
Président.
My question is addressed to you.
I'm
89 trying to understand the difference between your
interpretation of the data and on the general situation.
Because hearing you in your presentation and reading here,
just an example, when you say "given the poor environmental
performance of SRB facility."
So could you explain why it is so
different, your appreciation from the appreciation coming
from the staff from the company and our own appreciation of
data, real data.
So could you explain why it's different.
MS FEINSTEIN:
Pippa Feinstein for the
record.
Perhaps it would be helpful if I just
describe our impressions of the environmental performance
of the facility.
Am I understanding your question
correctly?
MEMBER HARVEY:
Well, I mean, with all the
data that are provided by the company, by the staff, so how
do you manage to get and say that it's a poor performance?
MS FEINSTEIN:
Okay.
So our references to
the poor environmental compliance of the facility is in
many ways historical, so understanding that there has
historically been considerable groundwater contamination
due to operations at the facility, and that these adverse
environmental impacts have continued to the present.
So
that's really what we mean when we're talking about the
90 historically poor environmental performance of the facility
and how this can still raise concerns, because there are
still levels of tritium in groundwater wells that are still
very elevated to this day.
MEMBER HARVEY:
Okay, I agree with you
that, well, eight years ago it was quite different than
today, and there has been some damages in the groundwater
and things like that.
But my idea was thinking in the last
five years, in the current licence.
So your appreciation
is much larger than only there.
But I will turn to Mr. Levesque.
And my question would be:
What is so
different in SRBT now that could assure the Commission and
the public that the future will be quite different, will at
minimum be as it has been during the last five years, and
that in the future, despite the fact that you could
increase the production and things like that, that the
result would be at least the same or better than it is
today?
What is so different in your structure, in your
culture?
MR. LEVESQUE:
Thank you very much for the
question.
I think that over not just the last
licence term but the one previous to that, seven years, we
completely changed our attitude.
I think we went from a
91 company that was looking at, like most companies out there,
at increasing the bottom line by just meeting your
emissions to what we are today, as continuously trying to
lower what our emissions are.
And I think our record over the past seven
years and in this licence term is well documented here,
where you can see that, despite increasing production
four-and-a-half-fold, our emissions have gone down at less
than half that rate.
And obviously the release limit,
we're still well within, but yet we're not satisfied with
that.
We want to keep lowering it.
If we could ever reach zero emission, it
would be our goal, and that's what we're striving to do.
That's why we said in our presentation that no less than
five per cent of our net profit would be basically
dedicated solely to reducing emissions.
And in not just
the attitude in trying to reduce the emissions from the
facility and the impact on the public, like we also want to
make sure that I think we inform the public as much as
possible.
I think a number of years ago we were a
lot more closed to the public.
And again, more from a
private company's point of view, not public, to basically
keep your business to yourself as long as you met the
regulations and the limits.
92 Well, now it's totally different.
We see
a huge advantage to basically share all our data with
members of the public as they ask, to instill the
confidence in them.
And you know, I think we've done that
and we'll continue to do that over the licence term.
We've
demonstrated that.
MEMBER HARVEY:
How many employees or
equivalent employees are working on environmental
protection and all of those reports you have to do to make
to the CNSC staff and with all the consideration with
health protection and public protection and things like
that?
How many people over all your staff are specifically
dedicated to that?
MR. LEVESQUE:
question.
And as my staff right now at the facility
is looking back at this and watching me, I better say that
all staff members are ...
--- Laughter / Rires
MEMBER HARVEY:
I thought you would
mention that.
MR. LEVESQUE:
reducing emissions.
... are involved in
But I can say specifically when I
discussed the Health Physics Team is made up of seven
members, including all the people that you see here today.
93 Myself and the vice-president, Ross Fitzpatrick, who own
the facility, we have seven employees who are dedicated at
reducing the impact on the environment and the public and
our staff from the operations.
And I think that's something that's
changed quite considerably.
I remember going to a hearing
in 2005, and there was one person doing that.
MEMBER HARVEY:
MR. LEVESQUE:
You?
You know, and I'd like to
take credit, but no, there was one individual that was
hired and that was reviewing the information.
say it was just over one.
So you could
But we've changed quite a bit
from 2005 to seven people now.
We've also retained some external
expertise.
That's also something I think that's helped
improve our facility, where we used to just be left with
our own thoughts and the things that we gained from our
operational experience and what we could research.
But now
we brought in some experts from other facilities, from CNSC
staff, people that had other experiences in the world,
other licensed facilities that could maybe apply things to
our facility.
presentation.
THE PRESIDENT:
Dr. McEwan.
MEMBER McEWAN:
Thank you for your
94 On page 9 of your written submission you
discuss what you perceive to be the limitations of the
funding model for the Participant Funding Program.
Perhaps
staff could just for the record identify how that process
works, I know it's an independent process, and how you
would like to see changes to it so that we could perhaps
help you a little more.
MR. RINKER:
Ottawa.
We have Adam Levine in
If Adam could respond, please, and set out the
steps of the process by which we go through setting the
amounts of funding for the Participant Funding Program,
please.
MR. LEVINE:
All right, thank you.
This is Adam Levine for the record.
I'm
the Participant Funding Program administrator here in
Ottawa.
So the Participant Funding Program is a
program set up in order to help Aboriginal groups,
organizations, and individuals participate and bring
valuable information to the Commission.
And funding
amounts are set up typically, and they're commensurate with
the type of facility, the type of renewal or licence
application before the Commission, and also looking at the
potential interest from the public, Aboriginal groups, and
95 also location of the facility, and also the complexity of
the project that's before the Commission as well.
And then once we receive all the
applications from the public, then we provide the
applications to an independent Funding Review Committee.
And the Funding Review Committee is made up of experts that
have expertise in both the nuclear sector as well as
environmental assessments and environmental matters.
And
they're independent from the Commission.
And they review all of the applications,
and they look at the applications with a number of
criteria.
In terms of eligibility, they have to meet the
eligibility criteria.
So they have to be a member of the
public, a not-for-profit organization, or an Aboriginal
group, et cetera.
And they also have to be within the
mandate, so their application and their specific proposal
has to be within the mandate of the Commission and also be
relevant to the proposal or the application before the
Commission.
So considering that criteria as well as the
potential to bring value to the Commission to help in
making its decision.
Those are all criteria the Funding
Review Committee uses.
And then they look at also costs of hiring
professionals and what typically that would cost in terms
of engineers or consultants and then provide
96 recommendations to CNSC staff in order to make a funding
recommendation.
THE PRESIDENT:
Thank you.
MEMBER McEWAN:
So how could you see that
process could be improved, given the comments that you've
made about your inability to hire a consultant?
MS FEINSTEIN:
Thank you.
This is Pippa
Feinstein for the record.
So it might be helpful to maybe outline
the experiences that we had in making the application and
ultimately getting partial funding for our intervention.
And I should mention that we are very
grateful for the funding that we have received, and it's
allowed us to participate to some extent in this
proceeding.
But we initially, Lake Ontario Waterkeeper
and Ottawa Riverkeeper, applied for funding to comment on
the public information aspect of the current application as
well as water quality in the current application.
We received a little less than two-thirds
of our funding and were told that we could only comment on
the public information program aspect.
It was problematic
that no reasons were given for this decision.
And additionally, we found out after the
fact that several intervenors didn't get the full amounts
97 that they requested, which was fine, but ultimately a
little over 25,000 was given to intervenors when we had
been told that 35,000 would be made available.
And so when
I enquired about this discrepancy as well, that many
intervenors didn't get the funding that they required to do
the interventions that they had planned to provide, I
didn't get any answers about that issue either.
So something that would be quite helpful,
I think, for intervenors would be that reasons for
decisions would be provided.
And I understand that there
may be some limitations with regards to the level of detail
of some of the deliberations that may have occurred, but
some kind of reasons would be helpful.
It would also allow
us in the future if we wanted to intervene to understand
better how applications were received so that we can
potentially make them more successful in the future.
MEMBER McEWAN:
So was the application
process for you as a group onerous, difficult, complex or
was it relatively straightforward?
MS FEINSTEIN: Pippa Feinstein for the
record.
I have to say that Adam Levine was very
helpful and helped us along the process.
There were some
aspects of the process that were difficult to understand,
but there was quite a lot of support in the application
98 stage of the process.
It was just receiving the decisions
that some improvements I think could be made.
THE PRESIDENT:
MEMBER TOLGYESI:
Mr. Tolgyesi?
One more.
On
intervenor's page 11 they are saying that, "More frequent
hearings are necessary due to recent regulatory changes."
Is the licence renewal one of the only
times when the new regulations or regulatory changes may be
integrated in the licence conditions?
MR. RINKER:
Excuse me.
when new regulations are incorporated?
MEMBER TOLGYESI:
Can I clarify
Was that your...?
During the licence
period it's a new regulation or it is regulatory changes.
So have you integrated that in an existing running licence?
You should wait until the licence renewal or you do
something to integrate that?
MR. RINKER:
Thank you for question.
It
is Mike Rinker for the record.
So during a licence period there may be
new CSA standards, there may be updated regulatory
documents and there may be revised or new regulations that
could come about.
So if it is in law a new regulation that
would apply on it coming into force, an updated or
clarified standards and regulatory documents would be
99 implemented by issuing a letter to the licensee saying we
have an updated requirement, you know, and there would be a
transition period and it would be implemented by way of the
licence condition handbook.
So as they come available, they would be
implemented.
We would not wait until the end of the
licence term to implement those.
MEMBER TOLGYESI: My understanding what
that you were saying that you should wait until the next
licence to make sure that the new regulations or regulatory
reviews are integrated.
So my understanding is not -- it
is applied right away or it is a transition period.
THE PRESIDENT:
Dr. Thompson, I see you
want to raise your hand?
DR. THOMPSON:
Patsy Thompson, for the
record.
The intervention on page 11 actually
refers to the recent MOU with the Department of Fisheries
and Oceans.
And I just want to clarify that the MOU with
the Department of Fisheries and Oceans gives the CNSC added
role in terms of the provisions of the Fisheries Act that
are related to fish and fish habitat.
And since the SRBT facility has no direct
interactions with surface waters or waters inhabited by
fish, there is no trigger to call upon that new agreement
100 with that new MOU with the Department of Fisheries and
Oceans.
So it's not relevant for this licensed activity.
THE PRESIDENT:
this?
Do you want to respond to
Go ahead.
MS FEINSTEIN:
Thank you.
Pippa
Feinstein, for the record.
So just to clarify, that is what we were
referring to was this memorandum of understanding.
And it
is quite new, so we are trying to understand how it impacts
the Commission's activities as well.
My understanding of the facility is that
it's very close to the Muskrat River and that runoff for
groundwater contamination can impact local aquatic biota
and or organically bound can accumulate in ecosystems
around the SRB facility.
So it would be helpful if I could maybe
just hear why that wasn't a concern to staff or why, in the
Staff's Commission Member Documents, which are about 175
pages, why they couldn't just have one sentence saying, we
didn't look into fisheries issues because we found that
they were irrelevant.
And then at least we can know that
they had been considered by Staff.
Thank you.
THE PRESIDENT:
Okay.
Staff, do you want
to respond why fish wasn't mentioned in the submission?
101 DR. THOMPSON:
record.
So just to add another element.
There is
a section in the Fisheries Act that deals with deleterious
substances.
And we do consider discharges of substances,
either radiological or chemical, to water with fish as a
consideration for our assessments and recommendations to
the Commission.
And I will ask Mr. McAllister to speak to
the assessment that staff did in relation to the Muskrat
River.
MR. MCALLISTER:
Thank you, Dr. Thompson.
Andrew McAllister, Acting Director for the Environmental
Risk Assessment Division.
As reported by SRB, the Muskrat River is
monitored on a regular basis.
Generally the values
observed are near the detectable levels on the order of 3
to 5 Bq/L.
When we look at that level or that
concentration in the river and we look at what is known for
the experimental data with respect to effective tritium
exposure on aquatic biota, really for aquatic biota we are
looking on the order of millions of becquerels per
kilograms of tissue to have an absorbable effect.
We are looking at, as we say, a few
102 becquerels per litre is what has been observed in the
Muskrat River.
to change.
And in the future we don't anticipate that
So as such, we didn't predict any impacts on
aquatic biota in the Muskrat River at all from the
operations of the SRB facility.
THE PRESIDENT:
Thank you.
Ms Velshi?
MEMBER VELSHI:
I have two parts to the
question, the first one is to Staff and then the second
part is to the SRBT, and it is to do with the term of the
licence.
And the intervenor has raised some concerns that
going to 10 years would result in diminishing the level of
public engagement with the facility and its operations.
And I know, Staff, in your submission part
of the rationale is that there is the annual performance
report review where members of the public can send written
submissions.
But perhaps you can expand on that and
talk about how can we make sure that there isn't any
reduction in the level of opportunities for engagement
available to members of the public, whether it is via
participant funding, whether it is by communities being
able to be present at hearings.
And how do you measure are
we reducing the level of engagement by going with a longer
licence term?
103 MR. RINKER:
Mike Rinker, for the record.
So during our licensing process and in the
middle of a licensing term and trying to inform the public
from a compliance perspective are both important things for
CNSC Staff.
We conduct -- in preparation for this
hearing, we were in the community doing what we call CNSC
101 to try to engage the community and let them know about
the facility, about our process, and how to get involved.
If we want to get into some detail, we
have a communication specialist, we will see her today.
But I would say if we looked back five
years ago where licence terms were every two years or five
years for this facility, we were not in front of the
Commission annually like we are no.
So I think the
opportunities for the public to engage the decision makers,
the Commission, has increased since, even with 10-year
licences.
So if there was a 10-year licence period,
we would be in front of the Commission reporting about what
is happening at SRB from a compliance perspective, how they
have been performing, SRB would be required to be there to
answer questions, and the public can intervene and have any
concerns raised.
If there is any changes to the facility
104 outside what is being licensed today, there would be a new
application to the Commission for decision.
This is not a
decision that staff would make.
So if the facility were to change in any
way outside the licensing basis, there would be a hearing
to consider that application.
MEMBER VELSHI:
But as we heard earlier
that it may not change from a licensing basis, but it could
significantly change its footprint as we heard just in the
last five years that emissions and the waste generated has
doubled, though well within limits, but it really has
changed its profile.
And it is really only during a licensing
hearing that the public really gets to hear about it and
talk about it, and then get engaged.
MR. RINKER:
Correct?
So two things in that.
First of all, it
is our view, and we have looked at a lot of the data, that
in fact the environmental footprint of this facility is
recovering from previous emissions.
So I expect that in
almost all wells the level of tritium is going down, not
going up.
Well, there has been an increase relative,
you know, going from 30 to near 70 from 2012 to 2017.
This
is still 95-98 percent lower than what it was 10 years ago.
105 And the licence limits are not changing
over the next licensing period compared to the last
licensing period.
And those licence limits are set to
narrow the environmental footprint.
Secondly, these results about the
environmental footprint and about the things that affect
the public; public does, what are the release limits, what
are the behaviour of groundwater, are things that we do put
in our annual compliance report and SRB does put on their
website.
So the public will be informed and can bring
those forward.
And if there are issues, some things that
we didn't expect, the Commission will be informed, the
Staff will be informed, and enforcement action can be
taken.
MS VELSHI:
And if the public wants to see
this information and wants help with their written
submission by hiring third-party experts, is there funding
available for them to do that or should funding be
available to them for that?
DR. NEWLAND:
Dave Newland, for the
record.
Yes, funding is available for those kinds
of activities.
MEMBER VELSHI:
Thank you.
And so the
106 second part of the question, which is to you, maybe you can
start off by giving us some indication of the level of
effort that is required in preparing for a licence hearing.
And also certainly from your addendum
submission, you seemed to do a whole lot of activity in
preparation for this hearing as far as engaging the public.
And how do you make sure you don't lose that momentum if
you were granted a longer term licence?
MR. LEVESQUE:
question.
Stephane Levesque, for the record.
If I can just -- I will answer your
question, but I will add a little bit to it.
For us, we have continued to report; the
data on our website, the groundwater monitoring on a
monthly basis since we got our licence five years ago.
We have continued to put in the quarterly
reports.
We have continued to do the yearly reports, we
have submitted it to staff and included the amount of
tritium that we processed. That was reported to the CNSC
and in our annual report, and the CNSC made the report to
yourselves once a year.
So it is nothing that stopped or that has
increased, that has always happened.
I think that where
there has been a disconnect with our public information
program is you can understand where we received two
107 inquiries over the four and a half years.
And suddenly
once we apply for our licence, we hear -- I think there has
been expressing concerns, 23 interventions.
I would like to point out that it is
important to note that only three of those were from people
from the community, the other 20 from groups or individuals
that live outside of the Pembroke or Laurentian Valley
area.
So that was the first time that we really
realized that other than these three people, that these
other 20 individuals or groups that have concerns regarding
our facility, how can we reach those people better?
And, believe me, once we are hopefully
issued a licence that is something that we are going to
focus on, to do that so that we can hopefully come back
here after the term of the licence and tell you that not
only did we answer what we I think have done is addressed
the concerns of the local community, but of those 20
individuals at large that we just found out have concerns
over the last couple months really.
And I want to meet
everybody's concerns and I want to answer all their
questions.
And having a licence for five years or 10
years doesn't make a difference because we are going to
report those activities as well in the annual compliance
108 report that is submitted to staff.
We have a large section
on public information initiatives and all our annual
compliance reports that they can see on our website.
And again, we are ready for any questions
from the public.
I think I was actually a little surprised
that during our annual reports I have seen interventions
and concerns written for other licensees who haven't
received any.
And maybe what we can do as a better job,
and that is why I said that we would post on our website
the annual report to the Staff, is to basically invite the
public to make comments.
So we are going to put it on our website
and send all our stakeholders a notice to say the annual
report from the Staff will be presented on that day, if you
want to make any comments, you can do so using this.
And
we will not just do the local community as we had done, but
these other 20 new interventions that we received.
THE PRESIDENT:
So I would like to
follow-up on this for the intervenor.
So the annual report is relatively new.
And inviting the public to make comments on the annual
report is relatively new.
Would you find it a useful
vehicle?
MS FEINSTEIN:
Pippa Feinstein, for the
109 record.
I think it is worth briefly mentioning a
point that I make in the written submissions that addresses
this fact as well.
And in our written submissions we did
do a literature review of a series of academic articles and
articles by practitioners looking at what makes public
participating meaningful.
And it was quite clear in their literature
that there were two aspects of public engagement programs
that could allow them to be classified as meaningful to the
public.
One was that these programs allowed for the public
to have some kind of influence over the process of the
engagement program.
The second was to allow members of the
public some kind of influence over the outcome and the
final decision.
Obviously a hearing allows for a greater
amount of public engagement in that we can present our
submissions orally and engage in discussion, which isn't as
available if it is just written submissions.
And my understanding of the meetings or
the annual reports is that we would be limited to written
feedback, and so there would be less opportunity to engage
in these types of discussions that we are having now.
THE PRESIDENT:
Okay, thank you.
We need to move on.
You have a final
110 word?
MS FEINSTEIN:
Pippa Feinstein, for the
record.
Thank you very much for listening to our
submissions, and I hope that they have been informative and
that you will consider them as you deliberate.
Thank you.
THE PRESIDENT:
So the next intervention is an oral
presentation from Dr. Ulsh -DR. ULSH:
Ulsh, yes.
THE PRESIDENT:
-- as outlined in
CMD-15-H5.3.
Dr. Ulsh, the floor is yours.
CMD 15-H5.3
Oral presentation by Brant Ulsh
DR. ULSH:
morning.
Thank you, Mr. Binder.
Good
For the record, my name is Dr. Brant Ulsh.
I would first like to thank the
Commissioners for allowing me the opportunity to
participate in this important hearing. Commissioners, you
may recall that I spoke to you last month at your hearings
up at Bruce.
And I was very interested to hear the
111 discussion after the previous presenter about the
importance of the effects of tritium on fish, because that
is one of the topics that I am going to be covering again.
It will sound familiar to you, but since
the audience is a bit different I will cover those points
again.
I came here today to offer my perspective
as a radiation safety professional, an independent person.
I have no affiliation with SRB.
And I have over 30 years
of experience in training in the radiation health sciences.
I am a certified health physicist and I hold a PhD in
radiological health sciences.
I also completed a post-doc appointment at
the McMaster Institute of Applied Radiation Sciences in
Hamilton.
The focus of my research has been on the effects
of low doses of radiation both on humans and on non-human
species exposed in the environment.
And based on this experience, I believe I
can offer you an informed scientific opinion on some of the
matters that you are going to be talking about today.
So we all know that the substance of
concern here is tritium.
And the question that we are
discussing is whether or not SRB has taken reasonable
precautions to ensure that its operations present no
significant threat to public health and to the environment.
112 And I think that the answer to that
question today is very different than the answer I would
have come up with 10 years ago.
According to the latest independent
environmental monitoring data available from the CNSC, the
maximum concentration of Tritium in surface water near SRB
is within the range of background, and these are
concentrations that are almost 1,000 times less than the
Canadian tritium drinking water limit designed to ensure
public health, protect human health.
But what about non-human organisms like
fish?
Is the tritium from SRB causing any negative impacts
in these species?
Well, I have been collaborating with
researchers from the Canadian Nuclear Laboratory just a
half an hour up the road, up Highway #17 from here, and we
were investigating exactly that question.
What are the
effects of low doses of tritium on fish species?
CNL researchers exposed fish cells to
concentrations ranging from natural background, which is
similar to the levels in water near SRB, that is the low
end of the range that we looked at.
And on the high end we
looked all the way up to 10,000 times higher than that.
We performed eight different biological
tests of biological effects.
And each test that we used
113 with the fish cells that we exposed to tritium was designed
to tell us something different about the health of those
cells.
The tests were very sensitive and they are
designed to detect effects that would occur at much lower
tritium concentrations than effects on whole fish or
populations of fish.
In order for a biomarker to be
useful, you have to see an effect well ahead of the time
that trouble happens.
So that is why we picked these eight
different tests.
Well, what did we find?
We found that
tritium concentrations up to 115 times higher than those in
fish near SRB actually protected fish cells from dying.
They didn't kill fish cells, they actually protected them
from dying.
We saw no evidence that tritium
concentrations, even 11,500 times higher than those in fish
near SRB, had any negative effects on the cells' ability to
reproduce.
So in sort, to wrap a whole lot of
research up into very few words, these tritium exposures do
not appear to be having any negative health effects that we
could see on these cells.
And our results are consistent
with a very loge body of past research and shows that the
levels of tritium in the water and in fish near SRB is far
below those that we would expect to cause negative effects
114 in fish.
So that is tritium in fish.
We know that very high doses of radiation,
thousands of times higher than those associated with
tritium releases from SRB, they do cause negative
environmental effects.
But our data, our fish data,
suggests that very low doses have the opposite effect.
Now, if this pattern of negative
consequences at high doses and no negative consequences or
even protection caused by low doses was only seen in fish
exposed to tritium, it would not be compelling.
But it is not just fish.
Research
conducted at CNL has shown that, for example, frogs from
ponds that contain low levels of tritium contamination were
actually more resistant to a large stress than frogs from
ponds where only background levels of tritium existed.
But it doesn't stop there.
We have seen
the same pattern in a variety of organisms ranging from
bacteria, yeast and algae to several species of plants,
frogs as I mentioned, mice, hamsters, rats, fish, rabbits,
deer, cows and, yes, even in human cells.
The resistance
to environmental stresses has been produced not only by
tritium, but other forms of radiation as well.
And we have observed the general pattern,
that moderate stresses, low to moderate stresses, anything,
from low levels of metals that are toxic in high
115 concentrations, ultraviolet light, heat, even exercise,
make living organisms more resistant to more serious
stressors as long as we are talking about low to moderate
doses.
I even recently found an article that I
haven't yet had time to read reporting that moderate
consumption of beer produces a radioprotective effect.
And
I am really kicking myself for not thinking of that
research idea when I was in graduate school.
As I said, I
haven't read the article yet, but it is an intriguing
proposition.
My point is that radiation, which is after
all a natural part of the environment, and has been since
the formation of the planet, it behaves like every other
stressor in the environment, it is no different.
Living
organisms respond to low and moderate stressors by ramping
up their defences and becoming resistant to more
significant challenges.
Evolution demands it, it is a
condition of living on planet earth.
So what does all this mean for SRB's
neighbours?
Well, you might hear claims that there is no
safe dose of radiation or that even very small doses or
radiation increase the risk of negative health effects.
Well, those claims are not supported by
the scientific evidence and they go against the advice of
116 scientific experts.
What does the evidence say?
Well, you
heard in the CNSC staff presentation earlier that several
epidemiology studies have been conducted looking at workers
and the public near Canadian nuclear facilities and they
have failed to show increases in risks associated with
tritium specifically, or with low doses of radiation
generally.
Again, our research shows that low doses
are protective or, at the very least, don't cause negative
effects.
There is simply no evidence that radiation doses
comparable to those resulting from tritium from SRB carry
any detectable human health risk.
Well, that's the evidence, but what do the
scientific experts say?
Well, scientists from around the
world have warned against claiming that there are human
health effects caused by radiation exposures as low as
natural background and as low as those resulting from SRB's
tritium emissions.
These include expert advisory bodies like
the International Commission on Radiation Protection and
the United Nations Scientific Committee on the Effects of
Atomic Radiation.
It also includes radiation protection
professional societies; for example, the Australasian
Radiation Protection Society, the Health Physics Society,
117 the International Organization of Medical Physics, the
Society for Paediatric Radiology and the American
Association of Physicists in Medicine.
There is a clear scientific consensus that
claims of negative health effects from even the smallest
doses of radiation are not supported by scientific evidence
and they are not credible.
The practice of radiation protection is
guided by the ALARA Principle, A-L-A-R-A, as low as
reasonably achievable, and the CNSC defines ALARA as a tool
in radiation protection used to keep individual, workplace
and public doses as low as reasonably achievable, and this
next part is very important, social and economic factors
being taken into account.
Now, the ALARA Principle does not dictate
that the CNSC must lead a march to zero radiation dose and
drive out of business any enterprise that could result in
even a trivial radiation dose.
That is not ALARA, and I'm concerned that
some people have forgotten that there is an 'R' in ALARA
and that 'R' stands for reasonable.
The ALARA Principle is based on the idea
that at some point below regulatory limits there will come
a point where social and economic considerations tell you
that it is no longer reasonable to continue to demand that
118 doses be reduced.
Now, given that the releases from SRB were
150 times lower than the public dose limit in Canada and
about 15,000 times less than the lowest dose known to be
associated with negative effects in humans, on that basis
it's my conclusion as a radiation protection professional
that ALARA requirements have been satisfied and I agree
with CNSC staff's recommendation that SRB, their request
for a licence extension be granted.
In closing, I think it's -- in one
paragraph -- I think it's appropriate for the community of
Pembroke to have a discussion about what businesses operate
here and the opinions and concerns of SRB's neighbours have
to be a large part of that discussion, and that discussion
should also be informed by an accurate presentation of
scientific evidence on the effects of low doses of
radiation.
My purpose in coming here today was to
provide the Commission and the members of the public with
that information that they will need as they go through
this discussion.
I wish you all success in this discussion,
and thank you for allowing me to speak today.
And I also
want to thank the Commission for the support that was
provided through the CNSC's participant funding program.
119 Thank you very much.
THE PRESIDENT:
Thank you.
Question?
MEMBER McEWAN:
Thank you for the
Dr.
McEwan...?
submission.
As I read through the intervenors'
documents, many of them started off by, again, as you did,
by a description of tritium in the environment, and then
there was a discussion of what effectively were described
as three forms of tritium in the environment, tritium,
tritiated water and organic bound tritium.
Could you provide us with an overview of
each of those elements, their relative importance and just
what they mean, please?
DR. ULSH:
Yes, I would be happy to.
I
think the three forms that you're talking about are HT,
tritiated water and OBT.
Tritiated gas -- tritium gas I think does
not last very long in the environment, it rapidly changes
to other forms.
HTO or tritiated water is just like normal
water, two atoms of hydrogen linked to an atom of oxygen,
it just so happens that one of those hydrogen atoms is
tritium or two, but usually one.
So tritiated water goes anywhere that
normal water goes and that means that tritium in HTO is
120 very rapidly diluted in the environment.
And the third form is organically bound
tritium and that has received a lot more attention
recently.
Because tritium is simply an isotope of
hydrogen, it goes anywhere in the body that hydrogen goes,
and organically bound tritium is thought to be more tightly
located with sensitive parts of the cells and, therefore,
it's thought that it has a higher biological effect per
unit dose, so one Sv, for instance, or one mSv of
organically bound tritium would have a higher effect than
one mSv of HTO and, you know, non-organically bound
tritium.
But the main difference, I believe, is
that organically bound tritium is cleared from the body at
a much slower rate than HTO.
It's held onto in the body
and it clears more slowly, so it delivers a larger dose.
MEMBER McEWAN:
So if you take that
delivery of a larger dose because of the binding within the
cell, would that increase in dose create a significant
difference to the calculations that you would do or, more
importantly, would it invalidate some of the experiments
that you've done which must involve some organic bound
tritium?
DR. ULSH:
organically bound tritium.
Yeah, they must involve some
I mean, we started with a cell
121 culture medium to which HTO had been incorporated, but of
course, the cells are going to take that tritium up and
bind it organically.
We didn't add organically bound
tritium from the beginning.
But to answer your question, yes, I would
expect that organically bound tritium would deliver a
higher dose, but we're talking about hundreds or even
thousands of times below the levels where we see adverse
effects.
So I don't believe that if it had been all
organically bound tritium, I don't think that would be
enough to show a negative effect.
MEMBER McEWAN:
But the experiments that
you've described in your submission would really combine
the effects of water -- tritiated water plus, or HTO plus
organically bound tritium in the output, so the results -the data that you report would include biological effects
of organically bound tritium?
DR. ULSH:
To the extent that the cells
that we expose to tritium incorporated that and bound it
organically, yes, it would.
The output that we saw would
include that factor.
MEMBER McEWAN:
Is there any way of
measuring that?
DR. ULSH:
Yes.
Yes, and we might even
122 have that data, I would have to look.
I haven't been asked
that specifically, but I think we might have data on both
HTO and organically bound tritium.
I would just have to
look.
MEMBER McEWAN:
So the other description
that was in a couple of the intervenors' submissions
related to the concept of radiobiological effect and I
think you alluded to it, the description of a higher effect
because it's bound and because it hangs around in the cell
longer.
So again, maybe you could just explain
radiobiological effect for the record in lay terms and say
whether or not you think that that is a valid idea or a
valid concept or not.
DR. ULSH:
Okay.
No, no, no, it's okay.
When tritium gets into a cell it goes to a
lot of different places, and if you think of a cell as a
bag of water, because that's really what it is, and there
are some very discrete targets inside that cell where the
DNA damage happens and the effects of radiation occur,
historically it's been thought that DNA is that target, and
I don't think there's any reason to doubt that, but if the
tritium is organically bound and it becomes -- it's brought
into very close contact with the DNA, it's even
incorporated into the DNA, then you can imagine when that
123 tritium molecule falls apart and emits radiation, it has a
much higher probability of interacting with the sensitive
part of the cell which is the DNA.
So I think it's a reasonable thing to look
at whether or not organically bound tritium has a different
effect per unit dose than tritiated water.
I think the
evidence to date is -- it kind of depends on what end point
you're looking at.
Epidemiology studies, I think that the
results have such a great uncertainty it would be hard to
tease out that effect.
We do have the potential to do that with
biological studies where we have much greater control.
The
trick to that area is interpreting your results in terms of
parameters that we really care about, like human cancer
risk or, you know, population level effects.
MEMBER McEWAN:
So I guess a final part of
that question, are there any data in the literature that
you're aware of that would actually validate or invalidate
the hypothesis of an increased RBE?
DR. ULSH:
Yes, there are both. There are
some that show that the RBE is, in fact, very similar, but
there are some that suggest that the RBE of -- I guess we
should define what RBE is.
Relative biological
effectiveness is an acronym that we radiation biologists
124 tend to throw around, and it's a measure of effect of say,
for instance, organically bound tritium compared to a
similar dose of a reference radiation, so say, for
instance, x-rays or gamma rays.
And when you say that the RBE of some type
of radiation like OBT is higher, that means it's more
effective at causing a bad biological effect.
I've seen evidence that suggest both.
I
think the prevailing attitude, certainly in regulatory
circles, is that OBT is more effective, but I've seen some
evidence that suggests that there's really not a lot of
difference.
I don't think it's a settled question yet.
THE PRESIDENT:
But just to bring it to
the SRBT, at the level of tritium that you see in the
ground, in the water, in the air and given all the
uncertainty in the calculation or dosage, in your opinion,
is there any concern here?
DR. ULSH:
course.
Is there any concern?
Of
Of course there is because the public is concerned
about tritium, and I think that's entirely reasonable.
If it was in my community, I would be
concerned.
And I think that the public has a right to
expect that SRB control their emissions.
Regardless of whether the resulting
125 tritium concentrations even approach the levels where we
see negative effects, it's reasonable to expect any
industry to control their emissions.
The question is, has
SRB done that to the extent that protects public health,
and my opinion is that they have.
Ten (10) years ago, I might have had a
different number.
When the CNSC shut them down, I think
that was probably an appropriate -- it's always easy to be
an armchair quarterback, but when I see the levels of
groundwater contamination that existed 10 years ago, that
would concern me as a radiation protection professional
just from the standpoint that I wouldn't have confidence
that the tritium emissions were being controlled.
Today, I think it's a different situation,
and SRB has demonstrated not just through their commitment
to increased staff, but when you layer on top the CNSC's
independent environmental monitoring program, that gives me
some confidence that SRB has turned a corner and is now
doing things a little differently.
THE PRESIDENT:
Thank you.
Questions?
Mr. Harvey?
MEMBER HARVEY:
One question.
I would like to have the staff comment on
the assertion that those low radiation doses could be of
126 some benefits to the human health.
Is that a scientific evidence, or...?
DR. THOMPSON:
So Patsy Thompson, for the
record.
So the answer is yes and no, and I -- so
yes, there is evidence that low doses of radiation like low
doses of metals and low doses of other stressors have a
protective or beneficial effect on cells.
And a lot of the
scientific studies -- and Dr. Ulsh talked about the ATP
measurements.
In a previous life, I looked at cadmium
exposures and ATP-ADP ratios, and it's essentially, you
know, organisms' reactions to stress and a way to
compensate.
And we normally see increases -physiological responses to stress that essentially bring a
benefit, so it's a well-known phenomenon.
It's well
established in the scientific literature.
The no part is, given the information how
cells and organisms respond to stress and that response to
stress where there is a benefit, there's a fine line
between having a benefit and then getting to a dose where
you're starting to see negative effects.
And that line
varies among organism and among cell types, and it's -right now, the scientific evidence and the positions taken
127 by regulatory agency is that the science doesn't allow us
to use that information very well to make regulatory
decisions, but the limits that are set are protective and
take into consideration all of the information that is
available, recognizing that we likely over-estimate levels
of effects and risks at very low doses.
MEMBER HARVEY:
And this is true for kids,
for babies, for -- is there a big difference between an
adult and a baby?
DR. THOMPSON:
record.
Cells react similarly because we -- you
know, the physiological responses and processes are the
same in cells and individuals.
There is a difference in
the resistance and adaptability, and there is some work
that has been done by the United Nations Scientific
Committee on the Effects of Atomic Radiation where they
have recently compiled all the literature on relative
sensitivities to various concerns of adults and concern,
for example.
And there are for certain types of cancers
where children are more susceptible to -- and other types.
But we do take that information and that scientific
evidence into consideration when setting limits and doing
our risk assessments.
128 THE PRESIDENT:
Ms Velshi.
MEMBER VELSHI:
Thank you.
I have a question for you on your Figure 3
on page 5 of your submission.
This is on drinking water
standards and guidelines.
And it just -- I'm just so taken aback
that there could be orders of magnitude differences from
one jurisdiction to another when everyone's trying to
manage the same risk.
And I know in your description, you talk
about maybe public dose limits being different, but is
there a move -- a movement to try to bring more
convergence?
As a layperson, this can just add to the
concern that people really don't know what they're talking
about if there's this much differences on what's
acceptable.
I'll ask any comment on that.
DR. ULSH:
Yes.
The figure that you're
referring to shows international drinking water standards
around the world, and they range from a high in Australia,
which I believe is 77,000 becquerels per litre.
It goes
through a number of other countries.
Canada's limit is 7,000 becquerels per
litre.
The U.S.A.'s standard is 740 becquerels
129 per litre, but that's based on an arithmetic mistake that
has never been corrected.
And yes, I think there is some effort
afoot to bring these regulations all into closer alignment.
It's kind of difficult because even the Australian standard
is at a level that is far below the dose where we see
negative effects, so of what benefit is it to lower it by a
factor of 10 or 100 or 1,000 or -- but there is some -- it
is somewhat compelling.
You know, if I live in, you know,
Australia, why is my limit so much higher?
I can't really explain why it's so much
higher.
Perhaps Dr. Thompson has some more insights into
that than I do.
But I do note that all of these are far
below the level where we see negative effects.
DR. THOMPSON:
record.
I'd ask my colleague, Dr. Mihok, to come
to the table.
Essentially, the data that is presented is
data that CNSC staff compiled a few years ago during the
tritium studies project.
The WHO essentially has made
recommendations based on the dose of 0.1 millisievert per
year, whereas the Australian guideline is based on one
millisievert per year.
130 They're all more or less an approach
that's based on the public dose limit and some provisions
for other sources of exposure, but I'll ask Dr. Mihok to
provide a better -- a more complete response.
DR. MIHOK:
Yes, good morning.
Dr. Steve
Mihok, environmental risk assessment specialist with the
CNSC.
Dr. Thompson has almost given you all the
answers you need.
Essentially, for 100 different reasons,
countries have taken the concept which is sort of in the
World Health Organization's standard of a dose of .1
millisievert, and how you translate that into a drinking
water standard or a guideline in becquerels per litre,
somewhere around 7,000, sometimes rounding it up, sometimes
rounding it down.
And even the EU, which is one of those
very small slivers, actually uses that number.
The number on the graph is sort of an
environmental monitoring indicator to react to situations
in the environment.
Australia really stands out as being
different, and when we asked them when we did the review of
drinking water standards why, it was essentially because
they have no issues with tritium and the health protection
agency which sets the standard just set it at one
131 millisievert instead of .1 millisievert since they had no
issues.
And the nuclear regulator in Australia
said that, "Oh, we would never allow any facility to
actually, you know, approach that standard in the way that
it released tritium into the environment".
THE PRESIDENT:
Can I -- I've just been
informed that in Japan now there's a tritium issue in
trying to get rid some of the contamination, and they're
using, if I understand correctly, 10,000 becquerel.
Anybody knows what the Japanese limit is?
Because they are now -- really are concerned with tritium
clean-up.
DR. THOMPSON:
record.
I believe the number is 10,000, but we
could do some verification perhaps over lunch and see if we
can confirm that number.
One of the -- I'll use the word "problem"
loosely.
One of the problems in Japan is that there were a
lot of commitments made during the actual emergency when
the Fukushima Daiichi reactors -- the accident happened.
And because of those commitments, there's essentially a lot
of work that is being done to try to manage contaminated
waters because of the likely unreasonable commitments that
132 were made to try to provide public reassurance at the time
of the accident.
And so there's a lot of work that's being
invested in terms of trying to find technology to remove
some of the removable radioactivity, and there's also some
work going on in terms of engaging the communities to get
permission, essentially, to discharge tritium at the higher
levels than the commitments that had been originally made.
CNSC staff was consulted by the Japanese
authorities about a year and a half ago to assess,
essentially, the document they were putting together to
serve as a basis for -- for moving forward on those issues.
So it's complicated.
Not just scientific,
but also a lot of social and public considerations.
THE PRESIDENT:
Mr. Levesque, you wanted
MR. LEVESQUE:
to add something?
opportunity.
I just want to add -- there was mention of
SRB 10 years ago, and I just want to put it in perspective
for the Members of the Commission and the public is that,
first, SRB technology since its inception in 1990 always
operated within its licence limit.
Always.
What's different is that, initially, SRB
was operating to a percent of its DRL.
That's how the
133 limit for most facility is set, by a percent of DRL.
Were
operating within five to 10 percent of their DRL limit, so
we were within the licence.
But that limit had no regard for
groundwater protection whatsoever, so unbeknownst to us,
yes, we didn't do enough of our homework.
We didn't realize operating to within that
limit would result in the groundwater problem that we had.
Since then, though, the limit and release
limit, percent of DLR that we're working to, is entirely
protective of groundwater, and I think that's the
difference between then and now because we understand the
mechanisms in groundwater.
The other thing that was mentioned is that
OBT -- I just want to make it clear to the Commission and
members of the public, and this is in our annual compliance
report, that when we calculate the public dose, we actually
calculate the OBT as a result of consumption of vegetable.
And it represents, from our dose -- I think you were told
by staff and ourselves that our dose has been less than
.007 millisieverts, so seven microsieverts, and the
percentage OBT of that is 3.13 percent in 2014.
So just so you can put that in
perspective, of our dose, three percent of it is associated
with OBT.
134 Thank you very much for allowing me to
make that comment.
THE PRESIDENT:
Thank you.
Question?
Okay.
I have a last question.
On page 6,
you make a statement that I'm just curious about because
it's really contrary to what we hear often.
Nowhere in the BEIR VII report does it
state that there is no safe dose of radiation.
I hear
quotes the reverse of that.
DR. ULSH:
If you have a PDF copy of BEIR
VII, go into it and search for the words -- the phrase "no
safe dose".
I got zero hits.
And that's why I say that nowhere does it
state that there is no safe dose.
Now, BEIR VII -- maybe I should explain
what BEIR VII is.
It's a report from the U.S. National
Academy of Sciences.
It was completed in 2005.
And it
examined the evidence on the effects of low doses of
radiation.
The conclusion of that report was that the
linear no threshold model, which assumes that there is an
increase in cancer risk at doses all the way down to zero,
that that was still an adequate basis to base radiation
protection standards on.
135 The thing that no one really talks about
is that there was another report issued about that time by
the French National Academy of Sciences and Medicine that
came to the exact opposite conclusion of that, that it was
no -- it was not justified to stick with the LNT.
So certainly there are some differences of
opinion about that.
It's also worth noting that since the
U.S. National Academy of Sciences issued the BEIR VII
report, two of the major sources -- major studies that they
based their conclusions on have changed.
The first is the 15 -- it's known as the
15 country study.
And you all may be very familiar -- you
may have heard of that because it was an epidemiological
study looking at nuclear workers in 15 different countries,
hence the name.
Canada was one of those 15 countries.
And ironically, when they started looking
at the results from the different countries, one country
stood out as suggesting very, very high risk compared to
the rest, and it was Canada.
So that initiated an effort to go back and
find out why in the world this was the case, and I believe
that they found some problem with the way that the dose
records from the early time period were incorporated into
the National Dose Registry.
I'm hesitant to go further than that
136 because I wasn't involved in that study, but I think that
that was what they found.
And without the Canadian data, there
was -- it was quite different results.
It suggested a much
lower risk at lower doses to the point where it wasn't
statistically significant.
The second piece of data that the BEIR VII
report relied on very heavily was the Japanese atomic bomb
survivors.
And periodically, the Radiation Effects
Research Foundation issues updates of the A-bomb survivor
data.
The latest, I think, happened in 2013 by a
fellow named Ozasa, O-z-a-s-a.
I assume it's a man.
I
can't always tell with Japanese names.
But that report looked at the latest
mortality data, and you have to read past the abstract.
You have to get down into the paper to see what the data
really say.
And basically, it showed that there is no
significant risk all the way up to 200 milligray.
Now, you have -- like I said, you can't
just stop at the abstract to find that, but when you go in
and you look at the dose -- response at different doses,
it's not statistically significant until you get above 200
milligray.
And that means that less than 200 milligray,
you can't say that there's a statistically significant dose
137 based on the Japanese atomic bomb survivors.
So there's been -- this trend has been
appearing over the years, but it's now to the point where
it's statistically significant.
So it would not surprise me -- I'm not a
member of the National Academy of Sciences, but I know that
they are preparing to revisit this issue, the risks of low
doses of radiation.
And it would not surprise me if
they're more cautious this time around in their
conclusions.
THE PRESIDENT:
Any final words?
Okay.
Thank you.
You have the final word
there.
DR. ULSH:
Oh, to me.
No.
Well, I would like to, again, thank the
participant funding program.
I know that you had some
questions about how that program worked with the previous
speaker.
I also did not get all the funds that I
requested, but I got all that I needed.
And my
interactions with the CNSC staff on the participant funding
program were uniformly positive.
The staff was very courteous, very prompt,
very professional, and I certainly support -- I certainly
appreciate the support that was provided.
138 Thank you.
THE PRESIDENT:
Okay.
resume at 1:30.
Thank you. We need to break for lunch and Thank you.
--- Upon recessing at 12:30 p.m. /
--- Upon resuming at 1:33 p.m. /
Reprise à 13 h 33
THE PRESIDENT:
Okay.
I'd like to move
now to the next submission, which is an oral presentation
by the Concerned Citizens of Renfrew County as outlined in
CMD 15-H5.4 and H4.A, H5.4B.
I understand that Dr. Hendrickson will
make the presentation.
Please proceed.
CMD 15-H5.4/15-H5.4A/15-H5.4B
Concerned Citizens of Renfrew County
MR. HENDRICKSON:
Mr. President,
Commission Members, ladies and gentlemen, I am Ole
Hendrickson, representing Concerned Citizens of Renfrew
County.
We have intervened at hearings on SRB and ACL for
139 more than 25 years.
We were probably the first to take
environmental monitoring samples in this area in 1998.
As Dr. Harvey asked, why is our impression
so different from the staff impression of SRB?
Well, we
expect that SRB will put its best foot forward and really
do a good job presenting its application, but we want the
CNSC to be independent, objective, unbiased and technically
credible.
And there are some problems, in our view, about
the Environmental Assessment Information Report and the
Independent Environmental Monitoring Program, such as the
statement that "'radioactivity measured in water, air,
soil, vegetation, milk, wine, fruits and vegetables ... are
within natural background levels'".
That sort of statement
raises red flags for a group like ours.
In CCRC's view,
there really isn't enough information yet about activities
in the material prepared by CNSC staff to accept that
recommendation that SRB will make adequate provision for
protection of the environment.
The rig stack, which is on the left,
amidst waste tritium gasses from filling rigs, the bulk
stack on the right from the bulk splitter laser cutter, and
formerly the reclamation unit, but you can see a lot of air
handling units also.
Could there be unmonitored radiation
emissions from air handling units other than the stacks?
That's a concern of ours.
140 The blue line is SRB's reported radiation
emissions over its entire 25 year operations, and we've
seen other graphs that have only started at the year 2000
and show that decline.
In 1994 the AECB granted an increase in
SRB's emissions to allow tritium reclamation and for the
next 10 years imported tritium light sources were crushed
in the reclamation unit and some of the tritium captured on
a uranium getter bed and the rest emitted through the bulk
stack.
This came up at the 2010 hearing, can we tell
exactly how much of the reduction was due to cessation of
reclamation, and I think we could if we were to look
separately at the bulk and rig stack data for the period
1995 to 2005.
And I believe that in future the annual
compliance reports, or ACRs, could provide data separately
for the rig and bulk stack, and that might help us
understand more what's going on.
After the 2006 hearings, the Commission
decided not to renew the tritium processing licence, saying
that the operation of SRB had resulted in unreasonable risk
to the environment, mostly due to groundwater
contamination.
As Mr. Rinker noted, in 2007 CNSC initiated
the Tritium Studies Project and the Synthesis Report from
that project, and there's a quote from that report, talks
about a value of 100 becquerels per litre of tritium which
141 can be -- represent a balanced consideration of science,
public health policy, and societal expectations.
The
report also says that for existing facilities there may
have to be higher levels, but those should be addressed by
the CNSC at the policy level in consultation with the
provinces.
Our concern is:
Is the current release
limit of roughly 448 terabecquerels low enough?
Is it
really low enough to protect groundwater or are we still
hiding behind the old 7,000 becquerel per litre limit,
which a lot of -- which at least two Ontario government
reports have said should be lowered to a hundred becquerels
per litre or 20 becquerels per liters.
And as was
discussed earlier, why these orders of magnitude difference
in protecting the public.
The orange lines are the predictions made
by CNSC staff in 2010 of what groundwater tritium levels
would be in four monitoring wells in 2014.
are monitoring data from the 2014 ACR.
The blue lines
And I think our
concern is that there does not appear to be good agreement
between the orange and blue lines, and this to us says that
the statement in the Environmental Assessment Information
Report by the staff that, "The relatively good match
between the modeling results and measurements provides
validation to [the prediction of] behaviors [in] tritium
142 [and] demonstrates that releases of tritium ... are under
control," may not be true.
We may not yet know what all
the sources of tritium are or how it's behaving in the
environment.
SRB's ACR show that between 2001 and 2006
drums of crushed glass were shipped to ACL Chalk River.
There was a five year hiatus in shipments of glass, as far
as I can tell, and then in 2012 shipments of expired
gaseous tritium light sources began.
And we assume that
these are mostly imported wastes from mostly the U.S. and
that they are being taken out of exit sign frames and
presumably shipped intact in as compact a form as possible
to Chalk River, where there is a licensed waste facility.
And we just think that this is an important activity which
has not been adequately addressed in the Environmental
Assessment Report and indeed in the whole CNSC staff CMD.
So, is our interpretation correct?
We
have found online Nuclear Regulatory Commission permits
allowing SRB's affiliate in Winston-Salem, North Carolina,
to ship waste exit signs to Pembroke.
So, is tritium
disposal a main part of SRB's business model?
There's --
you look on the website and you see disposal and recycling
of tritium.
And to my knowledge, tritium disposal is not
currently allowed.
Radioactive waste disposal is not
allowed by the CNSC.
We only store waste.
Even the Chalk
143 River facility stores waste.
And then this also raises the question of
how do we know how much of these expired tritium light
sources are coming in?
Can we accurately estimate the
quantities of tritium contained in these?
do.
It's not easy to
And this gets us back to some discussion earlier about
the possession limit for the facility and how much
processing you can increase and stay within that 6,000
terabecquerel possession limit.
If we -- if SRB wants to
increase the number of shipments, as -- and they seem to
have gone up in the past three years, it's going to be
difficult to maintain operations within that possession
limit.
And it's -- or there could be the incentive to have
more rapid throughput of tritium through the facility.
So,
there could be a fair limit on how much tritium can be
processed and it makes us wonder whether this strip mall in
Pembroke is really the right place to do this when the
eventual destination of these waste will be Chalk River.
Now, without going into details, the same
tritium gas used by SRB to make self-luminous devices plays
a key role in nuclear weapons arsenal.
And I want to skip
through this pretty quickly, but I would perhaps like to
have an opportunity to discuss this privately with
Commission Members because I do have concerns about safety
and security associated with large-scale imports and
144 exports of tritium, knowing that only a few exit signs or
perhaps a single Amersham container is enough to create a
real security risk if a terrorist group may have gotten its
hands on enriched uranium or plutonium.
And this is
something that has been raised by Kenneth Bergeron, who
is -- was a senior Department of Energy official with the
U.S., and he wrote a book in 2002, published by MIT Press,
where he warns that recent developments call for enhanced
vigilance about the availability of tritium and the
technology for producing it.
And just to show, that is taken from the
CNSC publication on Tritium handling that was part of the
Tritium Studies Project.
And that little metal -- the
larger metal container is the Amersham container and the
ones on the side would be the pyrophoric uranium tritium
traps that would be used.
And this -- a final, here, one further
concern, SRB does not own the building that it shares with
other businesses, such as Med-Ed(ph).
So if you look at
the back side of the building, here is -- here is an
expanded footprint of the building that SRB is in, and
we're concerned also about how that might influence release
of stacked gases, downwash, is there a possibility those
tritium gases could get into other facilities near SRB.
And also, you can see the construction on
145 the right side appears to us to have perhaps impacted four
of SRB's monitoring wells, including Well 24, which is one
of the few wells that's actually showing increases in
tritium and very significant increases.
Well 24 has gone
up from around a hundred becquerels per litre to 2500
becquerels per litre in 2014.
So I'll just leave that.
There are some
things that -- I know I've covered an awful lot of material
and really did my best to present that to you.
THE PRESIDENT:
Question.
Thank you.
Thank you.
Mr. Tolgeysi.
MEMBER TOLGYESI:
In your average
groundwater tritium concentration, and this is CMD from SRB
page 48, or I think it was in the -- this last intervener's
presentation also, the average groundwater tritium
concentration on the whole -- on Well MW06 decreased from
140,000 to about 27,000 in 2008.
reaching a kind of plateau.
Since it seems that it's
Now, I think the decrease was
one part due to production interruption, 2006 to 2008, but
since this plateau is still there and it doesn't move.
Does it mean that we reached a point where the emissions
and the -- where we reached a point where it's not further
decrease, or, according to predictions of the Commission,
it was a gradual decrease to very low levels?
Now, we have
for last six, seven, eight years a kind of plateau.
Could
146 we expect further decrease or how it fits with your
predictions?
It's a kind of revision of your predictions?
MR. RINKER:
I guess I first want to talk about the model and its
predictions and then I am going to pass the question over
to the Director of the Environmental Risk Assessment
Division.
But the modeling that was done to help us
understand tritium behaviour in groundwater,
particularly -- focused on this particular well but also
was applied to other wells, was trying to understand how we
expect -- there was an increasing trend, you can see it
around 2008 and 2009 in the figure you referenced - we were
trying to understand was that an increasing trend that was
real or is there something, other mechanism going on.
And
our assumption was -- or our -- the thing that we were
trying to test -- or answer was is the inventory of tritium
that's in the soil profile, the column of soil above the
groundwater, having sort of a latent effect on groundwater.
So, are we seeing tritium -- high values of tritium in the
soil overlying the groundwater slowly sleeping down into
that groundwater so we get that legacy effect?
really what we modeled.
And that's
We didn't -- although the model
was applied over longer years, I would say it's -- the
purpose or the question it was trying to answer was, you
147 know, are we seeing a latency effect of tritium stored in
the groundwater from previous emissions that would explain
the next few years of rising trends?
I think the model
would be weaker to say that it could predict, you know, in
a decade or five -- or into the future.
It was based on a
2006 soil profile to look over at a five or eight year
period as it trickles down.
So -- so I don't that we tried to model
going that far into the future, although we did play a line
to see how it looked, but I would say the model gets weaker
with time.
MEMBER TOLGYESI:
Did you look some
improvements in the models, you know, to revise the model
based on the data which you were collecting since the last
seven years?
MR. RINKER:
The model is -- is based on the coring of soil -- so of the
concentrations above the groundwater table, and we have the
data from 2006.
We don't have extra -- more recent data to
try to remodel into the -- into the future again.
MEMBER TOLGYESI:
You were saying that
when -- I'm sorry, I will stick to my question.
THE PRESIDENT:
Okay.
On this same
question, so the model shows that eventually it goes into a
steady state synthetically, let me use those words.
Is
148 there a value -- I guess what I'm concerned with, at the
end of the day you want to make sure that whatever reach
the river, the Muskrat River, is protected, right?
So is
the model eventually can be extended all the way down to
the river so you can actually figure out what's the
long-term synthetic value?
MR. RINKER:
I'll ask Andrew McAllister,
Director of Environmental Risk Assessment Division, to
answer that question.
MR. McALLISTER:
Thank you, Mr. Rinker.
That particular model, no, is not meant -was not meant to model out to the Muskrat River.
What CNSC
staff did as part of its assessment, as part of the CMD
looked at really very much a bounding scenario.
So if we
look at the well in question that Dr. Hendrickson and
others have mentioned, we took the highest tritium value
observed, which is around 156,000-and-so becquerels per
litre, and then took some very conservative assumptions to
have that essentially move downgradient into the Muskrat
River.
So we looked at a -- we conservatively looked at
100 x 100 metre area.
We took the -- I'll say the highest
groundwater gradient velocity that we could find based on
very localized conditions of 14 meters per year and moved
that downgradient, without the natural hydrological
processes that do happen, like dispersion and others, we
149 only accounted for radioactive decay, and had that
basically discharge into the Muskrat River, and the
resulting -- the result of that was less than 1 becquerel
per litre increase.
And we have been seeing the range of
values of Muskrat River through the monitoring being around
3 to 6.
And so, that's -- that's the basis for which we
conclude with confidence that we don't foresee any impacts
on the Muskrat River from the groundwater.
THE PRESIDENT:
So -- but you're starting
to have more and more data, so will you be able to then
project or fake the model so that you can actually keep
tracking as to how the plume -MR. RINKER:
So it is possible to improve the model with taking more
core samples, or probably more straightforward is looking
at air emissions and trying to find correlations and making
predictions.
However, it's very difficult to be so
precise, and to suggest that the model would be -- would
be -- would solve the question that's being asked is less
certain.
And I think the monitoring data itself, rather
than modeling and predicting, measuring and seeing the data
on a quarterly basis and watching it trending lower and
lower, and having a good understanding of the hydrogeology
to know that Muskrat River has been receiving tritium by
air deposition for many years and it hasn't shown
150 concentrations beyond a few becquerels per litre, the model
is not going to necessarily provide us with more
confidence.
It may just provide us with some answers to
some more theoretical questions.
THE PRESIDENT:
MR. LEVESQUE:
Mr. Levesque.
If I
can just add to that with some data that's in our
submission, on page 49 of 72.
That's the submission from
March 13th, in which we state that we have performed a
number of other monitoring activities, and one of the
indications within groundwater is what we find in
precipitation.
We find in precipitation concentrations of
on average over the licence -- the licence activity of the
five years, 75 becquerels per litre, and most specifically
in 2014 of 42 becquerels per litre.
Now, those
precipitation monitors are between 250 to 500 meters from
the facility, so close to where the Muskrat River is.
So,
you're talking about that small a proportion.
If you're looking at concentrations in the
well, have they reached a plateau, we don't believe it has.
We've taken soil samples a year ago in June and some
exactly at the stack, which is indicative, you can
understand, of where the concentration will be in future
years, and what we found, and that's even before dilution
due to the years and decay, that the sample was just over
151 10,000 becquerels per litre.
So over time as it progresses
through the soil and gets diluted, the concentration in the
well will be even further below that.
MEMBER TOLGYESI:
You were saying also
that there is no processing during precipitation events and
this is mainly due to -- to prevent any -- any tritium with
precipitation, weather going in the ground.
Now, when
there is nice weather you do produce and you emit; there is
emissions.
Eventually even if you stop during a
precipitation, that tritium is on the ground, so with the
precipitation it will seep through the ground.
So do you
have any modeling which -- which will show what's the
effect – what's the effect of suspend processing during
precipitation?
MR. LEVESQUE:
Stephane Levesque for the record.
A number of years ago
before we instituted that -- that precaution, we found that
concentrations on site, if we processed while we were
operating, were in the tens of thousands of becquerels per
litre near the stack.
And after we saw processing and made
the same measurements, you were getting a few hundred.
So
it's made a significant impact into the concentrations in
water near the stack and it's hard to qualify because all
the atmospheric models that are out there are really based
on having a certain proportion or range throughout the
152 year, so they actually grossly overestimate what the
concentrations in groundwater would be, but we know from
our measurements it makes a huge difference.
MEMBER TOLGYESI:
MS THOMPSON:
record.
Staff, something to add?
Patsy Thompson for the
Perhaps if I could try to put all the pieces
together.
So when we started having concerns around
SRBT was mainly because of very elevated concentrations
around the site.
And through the various investigations we
did, the sources remained -- important sources were
entrainment of tritium around the facility, from the roofs
and down, and the stacks.
We also, as a result of the --
of the tritium studies, looked at what was being done in
other jurisdictions.
And from that point of view, we -- we
did, rather than propose to the Commission a limit based on
1 milliSievert per year, proposed a limit that over time
would reduce the amount of tritium going out the stack and
being entrained through rain events and other precipitation
to the ground.
Implementation of that limit and the
improvements that SRB have done on their facility have
resulted in decreases in levels of tritium in groundwater
and that is seen by values not just on site but also
off-site, where tritium values in -- in the wells have gone
down.
153 The questions that have been asked in
terms of could we do better in terms of predicting
long-term performance – excuse me – one of the -- one of
the reports that was done for the Tritium Studies Project
looked at the ability of models like the CSA N288.1 model
to take a source projected in the atmosphere through
entrainment and see what the results in groundwater would
be.
We did do a lot of validation with that, the
modelling, with some of the results that exist around
Canadian nuclear facilities and we saw that the models were
conservative and tended to over-predict groundwater
concentrations.
And so if the -- if we were to redo such a
modeling, it's totally possible to do it with starting as
if the ground has no contamination, doing the modeling for
ongoing emissions, seeing what we would see in groundwater,
but what we know is that the models are conservative and
would tend to over-predict.
And so if the real question is how long
will it take for levels to reduce, then it is really true
measurements.
If the question is is the limit sufficiently
protective to not have any contamination of groundwater,
that's quite a different question and it is, in my view,
impossible for SRB to operate with absolutely no
entrainment of tritium in groundwater, but what they have
done is reduce emissions and they're managing their
154 operations, orders of magnitude before than they did in the
past and they've continued to look at ways of reducing
emissions.
And so from that basis there is certainty that
groundwater levels will decrease, continue to decrease
until a steady state is reached, and the levels that we're
seeing have essentially no health concerns and will
continue to decrease and -- and continue not to pose a
concern.
MEMBER TOLGYESI:
You were saying that the
modelling is quite conservative, which means it really
over-estimates the values.
Now when you're looking at the
intervenor's slide 5, where he compares actually what's in
against the predictions, they are quite higher.
So if the
predictions were conservative, it's kind of unbalanced
there.
DR. THOMPSON:
So, Patsy
Thompson for the
record.
So we're talking about two different
models.
Mr. McAllister will explain the model that is
presented in the staff's data.
The model I was talking
about is if you take emissions, do atmospheric dispersion,
and then look at the factors that would cause tritium to
come down to the soil and then move to groundwater.
type of model has been seen to be conservative.
let Mr. McAllister explain that other part.
That
But I'll
155 MR. MCALLISTER:
Thank you.
Andrew McAllister for the record.
Just to revisit, and Mr. Rinker mentioned
some of the earlier in the presentation, but the model that
was done in 2011 relied on the soil profiles from the
monitoring wells and was looking at average hydrological
and hydrogeological parameters, such as I guess constant
rate of permeation through the soil column, tritium being
fully mixed.
So there were some average values that were
used in that model.
And you know, it generated
predictions, it generated trends.
And when we look at
that, given the model, given the intent of the model over
the most recent past licensing period, we do see a good
match of the trend of the information relative to the
monitoring information that was collected.
Do we see variability in the monitoring
information?
system.
Absolutely.
We're monitoring a natural
Natural systems are complex by nature.
A lot of
things can influence a given monitoring sample at a given
location.
It could be related to fluctuations of releases
in the air, precipitation, surface-water runoff,
infiltration rates -- and that's just getting us in the
vertical aspect.
When we start moving horizontally,
there's aspects around radioactive decay, dispersion,
retardation, and other hydrogeological processes.
156 So we're not surprised that we're seeing
variability in the actual monitoring data.
But what we do
take comfort in is that the trend of it is very similar to
what was predicted; it's a fraction of what was happening
historically; and that the residential wells and the
Muskrat River remain protected.
THE PRESIDENT:
Thank you.
Monsieur
MEMBER HARVEY:
Merci, Monsieur le
Harvey.
Président.
I want to go to go the written submission
by Dr. Hendrickson under H5.4.A, page 2.
There is a table
there, "Tritium Wastes Shipped to AECL."
And there is a
comment right after, on the other page, at the top of page
3.
"The total radioactivity in these
shipments amounts to thousands of
TeraBecquerels per year.
We urge
Commissioners to confirm the correctness
of this interpretation during the
hearing."
So I would like to have some SRB comments
about that table here, and to explain the last three lines.
For example, the type of packages, what volume that
157 represents, and the nature of the content of those
packages.
MR. LEVESQUE:
record.
If we look at Table 1 in Dr. Hendrickson's
presentation.
If I go back in time a bit, I'd like to
remind members of the Commission that when we first
reapplied for our licence in 2008 that we had discussed in
detail with the concerned citizens and the members of the
First Six Years where they were looking for the most for
SRB to do to support our licence application.
And one of the main things was for us to
stop using the reclamation unit, which consisted in taking
tubes or lights out of our rejects and basically crush them
to try to recycle the gas.
that was profitable for us.
And it really wasn't a process
It was really something, again
as I mentioned earlier, we did it for an after-sale service
for our customers.
So we agreed to do that to keep members
of the public happy.
But right away what would happen as a
result is we still take back product from customers that no
longer meet the requirements that they have the products
for, for brightness.
So what we do now is we take, for
example, an exit sign.
We assess the brightness of it, see
158 if it still meets a building code, whether it's the
building code the customer wasn't meeting any more or
another building code where we can resell those lights
within the sign.
And if we can't use them, we take the
light sources out of the sign, we package them, and we send
them to a licensed waste facility.
And that's where you see those numbers,
where before what we would have done is we would have put
it in our reclamation unit, crush the light sources, and
re-use the tritium and send crushed glass instead to a
licensed waste facility.
So really what it has done is
essentially changed the crushed glass to sending light
sources to a waste facility.
And if you're asking me about quantities,
I got the numbers for 2013 and '14.
We've imported from
all various customers as part of returning their signs or
giving them new signs or them just disposing of them with
us, we've taken back approximately 20,000 exit signs in
each of those two years.
And I have the detailed reports.
And
that's where we're proposing -- I said in my presentation
to Mr. Hendrickson and other members of the public who have
concerns about that -- to basically put in our Annual
Compliance Report all our import per countries and get
159 those details, so that people know exactly what we're
importing and where it's from.
MEMBER HARVEY:
What percentage of your
production does represent those --MR. LEVESQUE:
Depending on the year that
we're talking about, I would say maybe about 40 per cent of
the production that we're taking back right now.
You got to realize as well that now with
having Shield Source, our then competitor, being no longer
in business, we're also taking back signs that come back
from them.
Because we have their customers looking for new
signs and they're looking to dispose of the old signs.
And we re-use as much of the sign as we
can.
And if we can't, we take those tubes, package it
properly according to the regulation, and send it to a
licensed waste facility -- a licensed waste facility within
Canada.
MEMBER HARVEY:
And essentially now the
radioactivity, the content is just shipped to AECL and -now.
I mean those, there is some radioactivity in the
waste, and it goes to AECL, and then it goes to a landfill
or -- what does happen after that?
MR. LEVESQUE:
record.
160 AECL is one of the places -- actually,
right now it's the only place that we send these packages
to.
From what I understand, they go in long-term storage.
MEMBER HARVEY:
Okay.
THE PRESIDENT:
Well, maybe now is the
time to get CNSC to explain what are the rules of waste
disposal.
I think the intervenor mentioned that he thought
that waste disposal is not allowed.
I don't know, I'm
putting words in your mouth.
So what are the rules?
And maybe, while I
know you want to go fast through the security, we cannot go
through fast through the security.
I'd like some comments
about safeguards and the protection of this material.
So
why don't you start to illuminate us.
MR. NEWLAND:
Dave Newland for the record.
While we sort out our answer on the waste
disposal and storage, I'll have Mr. Awad and his staff talk
about safeguards on import and export of tritium.
MR. AWAD:
Raoul Awad for the record.
I'm
the director general of Security and Safeguards.
First, tritium is a controlled material
under our regulation.
It requires a licence for export and
a licence for import.
The most important thing, it's --
see, in some of this submission -- tritium in the dispersed
form, which is exported and imported by SRB, is not useable
161 for nuclear weapons.
That should be clear.
However, it's
under our regulation and we control it under our
regulation.
With regard to the safeguard, we removed
the clause or the licence conditions of the safeguard
because we have -- it's covered under our regulation.
And
maybe my colleague Karen could give you more explanation
about the safeguard issue.
MS OWEN-WHITRED.
For the record, Karen
Owen-Whitred, director of the International Safeguards
Division.
You asked what the rules are related to
safeguards generally.
So let me just quickly explain that
there is an international system called Safeguards.
And
what we mean by that is the control of nuclear material
that could be used in a nuclear weapon.
Nuclear material
within that system has a very specific definition.
uranium, plutonium, or thorium.
It's
These are the three
materials that could be used -- that need to be used when
you're making a nuclear weapon.
If I can use a very
simplistic metaphor, they're essentially the bullets in the
weapon.
In order to control the spread, the proliferation
of nuclear weapons, the International Safeguards System
controls those inputs, the three materials that need to be
used in order to develop a weapon.
162 So I would just point out as well that I
think there's some confusion.
Although tritium can be used
in a weapon in order to boost yield, if you don't have one
of those three materials to begin with -- the uranium, the
plutonium, or the thorium -- you cannot create a weapon.
So the system is aimed at controlling those three and, by
extension, controlling weapons as a whole.
THE PRESIDENT:
So tritium is not part of
the safeguard process?
MR. AWAD:
Exactly.
safeguard.
Tritium is not under IAEA
However, our regulation, which is based on the
nuclear supplier group, controls tritium, because tritium
could be used to boost the yield of nuclear weapons.
THE PRESIDENT:
So why was it in the
clause to start with?
MR. AWAD:
Why was it...?
THE PRESIDENT:
the licence to start with; right?
removing it from the licence.
I mean, I think it was in
I mean, you're now
Why was it inserted to start
with?
MR. RINKER:
If we went back five, seven, eight years
ago to previous licences, the condition was there.
The
program was not rated and there was an exemption in place.
163 So it was a condition to do something that isn't
necessarily required.
It was a redundant condition.
MS OWEN-WHITRED:
Sorry, if I may just
add -- Karen Owen-Whitred for the record.
That original condition that was in place,
it was focused on the depleted uranium which is used at
SRB.
It was not focused on the tritium.
THE PRESIDENT:
So there is some still --
depleted uranium?
MS OWEN-WHITRED:
Karen Owen-Whitred.
That is correct.
And as has already been
stated, any requirements that may be expressed by the
International Atomic Energy Agency, which is essentially
the UN organization that administers international
safeguards, should they have any safeguards measures that
they wish to apply to that small amount of depleted
uranium, the CNSC has the regulatory capability to do that
through the general regulation.
The existence of this specific licence
condition, as has been stated, is redundant, and the
removal of that condition does not in any way affect the
IAEA's ability to apply safeguards should it request those
measures to that depleted uranium at this facility.
THE PRESIDENT:
you like to react to this?
Dr. Hendrickson.
Would
164 DR. HENDRICKSON:
Ole Hendrickson for the
record.
That's true that tritium is not in itself
a -- you can't make a weapon just from tritium.
But you
can certainly make a much more powerful weapon from the
combination of tritium and enriched uranium or plutonium.
So I think it's still extremely important to keep controls
on the movement of tritium, and particularly when it's
attached to depleted uranium.
And also on exit signs,
because there could be a possibility of re-extracting that
tritium from an exit sign.
I don't know the details of the IAEA
regulations for the different substances from which you can
make nuclear weapons.
But I just wanted to alert the
Commissioners that it's extremely important to make sure
that tritium does not fall into the wrong hands.
And I
hope that you'll make sure that that is the case.
THE PRESIDENT:
So if I understand from
staff, all the security rules still apply here?
MR. AWAD:
Raoul Awad, for the record.
All the rules apply.
something:
Let me just clarify
removing the tritium for military use from the
sign doesn't make any use for nuclear weapons, because it's
165 in a dispersed form.
It's a component which is not
easily -- you know, in theory you can remove it.
But
practically, it makes it useless for nuclear weapons, this
dispersed form.
THE PRESIDENT:
Thank you.
Question, Ms
MEMBER VELSHI:
So it's not on safeguards
Velshi?
but it is on export of tritium in your light.
What are the restrictions on who you can
export it to?
And I see you've got just a handful of
countries that you export it to.
obligations post-export?
And what are your
And do you always have to accept
the used lights back when they no longer have a need for
them?
MR. LEVESQUE:
record.
No, we don't always have to accept them.
It depends on the manufacturer.
they're trying to send back.
It depends on the product
And we have refused some at
times if we weren't sure exactly what product it was that
was done by one of our competitors.
Regarding our obligations for export,
every time we want to export to a new customer, we have to
apply for an export licence and we have to show the end
use, what the lights are used for, or the product, in this
166 case.
So the CNSC reviews that and issues the licence or
asks for more information based on what we've submitted.
MEMBER VELSHI:
Maybe I'll turn to staff.
Have there been cases where you have not accepted an
application for an export licence?
MR. AWAD:
You mean particularly for SRBT?
MEMBER VELSHI:
MR. AWAD:
Particularly for SRBT.
I will ask my colleague, David
Reinholz, who is in Ottawa, to answer this question.
MR. REINHOLZ:
David Reinholz for the
record.
No, in the past we have no record of any
licensing -- or any application from SRB that was denied
for issuance.
MEMBER VELSHI:
Thank you.
So are there specific countries in your
licence acceptance process that you wouldn't allow these
light fixtures to get exported to?
MR. REINHOLZ:
We do have multiple
guidelines for following when issuing an export licence,
specifically for tritium.
One of those is the 1986 Tritium
Export Guidelines which were published by the Government of
Canada.
They stipulate exports of tritium to any state as
well as exports of tritium to a state party to the
167 Non-Proliferation Treaty.
There are different requirements
for a Non-Proliferation Treaty state versus any other
state.
As well, there are also other regulations
within Canada, such as the Special Economic Measures Act,
as well as the UN regulations which may prohibit the
export, depending on where it is going.
MEMBER VELSHI:
Thank you.
THE PRESIDENT:
Dr. McEwan.
MEMBER McEWAN:
I'd like to explore Dr. Hendrickson's
submission, page 6.
I guess particularly the second,
third, and fourth bullets at the bottom of the page, where
he discusses the fact that SBR is a tenant in a building
which has other tenants, and safeguards for those other
tenants.
Are you confident that there is no risk?
Are you confident that you would be able to be aware of a
risk should that develop?
MR. NEWLAND:
Dave Newland.
Are you referring to 4 or 4A?
MEMBER McEWAN:
MR. NEWLAND:
MR. RINKER:
Is it 4?
No, it's 4A, sorry.
Four-A.
168 Maybe I could start the answer, and if we
need to go a little bit deeper, we can explore use of
specialists.
But in general, there's a fairly
sophisticated monitoring program that occurs within SRB,
the facility itself.
There's many different rooms within
SRB's control that are zoned.
Zone 1, for example, would
be the type of activities as offices and meeting rooms and
so on.
And so I think it's fairly evident that we
have an understanding from a regulatory point of view of
where the tritium is going and where it's not going.
So
the tritium within the building from an SRB perspective is
managed correctly and by every indication it's not moving
to other parts of the building.
MEMBER McEWAN:
"By every indication"
means...?
MR. RINKER:
So it is monitored and there is
calculations.
MEMBER McEWAN:
Thank you.
THE PRESIDENT:
I see somebody.
Some help
is coming along, here.
DR. THOMPSON:
record.
169 Just to give the help some time to get
organized, the questions are related to other workers.
And so Ms Sheri MacDonald will talk about
some of the measures within the SRB facility to control
exposures to workers.
And Mr. Mike Jones is verifying -- my
recollection is that one of the critical groups for which
we calculate -- we've designed a monitoring and a reporting
of doses -- is a worker in the facilities around that is
not employed by SRB, but this is being verified.
And
perhaps Mr. Levesque could confirm.
MR. LEVESQUE:
Stephane
Levesque for the
record.
Yes, as I've mentioned before, when we
calculate the maximum possible public dose to an
individual, we assume that the individual is an individual
that works in the facility right next to ours and that
lives in the community right closest to SRB.
Another thing that we've done in the past,
we have what's called an air monitoring station, a passive
air sampler directly in our neighbour's facility.
And
we're using that there just to confirm that the doses
within that facility were negligible.
And after the construction of this
extension is done, just to confirm what our assumptions
170 are, is we're going to do the same again and compare the
data that we have from before this one.
MEMBER McEWAN:
So, again, if I can just
ask a very naive question around the new construction:
Is
there any risk of contamination of the new construction as
it's being constructed from the stacks?
MR. RINKER:
So will there be any exposure whatsoever?
I think when anyone is working in and around those stacks
there is entrainment.
tritium.
You are exposed to some levels of
But people have worked, and we've measured
tritium levels in and around those stacks and in and around
the construction area, and the dose consequences are not
anywhere near those that would cause a health effect.
So
to say that there's zero emissions or zero tritium is not
correct, but I'd say that risk is extremely low.
THE PRESIDENT:
they going to wear dosimeters?
Well, let me ask you, are
Because I'm just trying to
figure out will it be such that it will be measurable?
DR. THOMPSON:
record.
So I will ask Sheri MacDonald to explain
the monitoring that is done of workers, because wearing
dosimeters is not appropriate for tritium.
And then we
will talk about what is done for essentially workers and
171 members of the public within the strip mall or the other
buildings.
MS MacCDONALD:
Sheri MacDonald, for the
record.
The workers, as Dr. Thompson mentioned,
wearing dosimeters is not effective, they will not be
useful.
So at SRBT they have a bioassay program in place.
So workers who work in Zone 3 are
monitored on a -- submit a urine sample on a weekly basis,
and the other works submit on a bi-weekly basis.
And those
samples are measured to determine the amount of tritium in
their system to determine if there is any kind of dose
received.
And they have action levels in place for
those levels.
And as you can see over the licensing
period, the average annual effective doses to workers have
been consistently low, .1 to .2 mSv, and the maximum has
reached over the licensing period 1.9 mSv.
they are very low.
So essentially,
And these are the people who worked
directly with the materials all the time.
DR. THOMPSON:
record.
If I could add.
A number of years ago
members of concerned citizens for Renfrew County had raised
concerns about exposure to tritium of people working in and
172 around the SRB facility and had essentially submitted a
urine sample from one of the individuals.
At the time Mr. Bertrand Theriault, who is
in the room here, our internal dosimetrist, had essentially
taken the urine tritium concentration, and we had provided
him the air monitoring data that was being measured at the
time.
And he essentially used the dosimetry models and
came up with, from the air concentration to the urine value
there was good concordance.
And so moving forward, measuring air
concentrations around the SRB facility in other parts of
the buildings or around the facility for members of the
public gives a really good measure of tritium exposure and
tritium dose. So there was, at the time, good concordance
between air data and urine values.
MR. LEVESQUE:
record.
If I could just go back again to how we
calculate the maximum dose to a member of the public.
We
do assume that that individual is working or is standing
outside right by the passive air sampler where the
construction is occurring.
And we calculate the dose due
to inhalation, we call it at work, and do the skin
absorption, and the total of that works out to less than
.35 microSieverts for last year.
173 So you are looking at .35, and we
estimated that in total that person would be getting 6.8
microSieverts.
So that would be -- it is a very small
dose.
THE PRESIDENT:
So are you going to
subject them to bioassay tests also?
MR. LEVESQUE:
record.
No, the number would be so low it would be
barely detectable, it would be less than people that are in
our facility working in the office area.
THE PRESIDENT:
Thank you.
MEMBER McEWAN:
So, to be clear, you don't
believe there is any value in monitoring the new
construction when it is finished, just for public
reassurance?
DR. THOMPSON:
record.
Our assessment is that the monitoring
program that is currently in place with air monitors and
other measures is sufficient.
If there is a request for
reassurance of workers or construction workers on the site,
that data can be provided and essentially people, you know,
walk through what the data means.
But, you know, the fact that there has
174 been monitoring very close to the stack for other places,
you know, on the same building area, for a number of years
we verified those measurements.
Should give confidence to
anyone working in this area.
MEMBER McEWAN:
Dr. Hendrickson, any
comments?
DR. HENDRICKSON:
Well, thank you.
Ole
Hendrickson, for the record.
Our concern was -- as much as anything, I
am not an air emissions expert.
But I am aware that
sometimes stack gas plume behaviour can be changed when the
building footprint changes.
And we thought it might be prudent to look
in to the possibility that the larger building footprint
might affect the way that the plume would get down and
perhaps -- I hoped this couldn't happen, but as a
non-expert, just to raise the possibility that there could
be some uptake of that plume directly into the ventilation
system for the expanded facility.
That was the main concern that we were
hoping could be addressed.
Thank you.
THE PRESIDENT:
And to that concern,
presumably they will continue to monitor.
And if there is
a detected deviation, presumably they will react to it.
Is
175 that -- I have it right?
MR. RINKER:
Yes, certainly monitoring.
But in
addition, the stack design and how the stack is functioning
is also something that is evaluated on a periodic basis.
So any changes like this would be incorporated into that
assessment.
THE PRESIDENT:
And while we are talking
about this construction, I think the intervenor mentioned
that he was worried about whether the construction will
impact Well 24.
Will it impact Well 24?
That is a key
well that gives some readings.
--- PAUSE
MR. LEVESQUE:
Just one moment, we are
just trying to confirm information.
THE PRESIDENT:
While they are looking, go
ahead Mr. Tolgyesi.
MEMBER TOLGYESI:
It is one to SRB.
Isn't
the other ventilation then through stack exhausted from the
facility because we saw lots of exhaust on the top of the
building.
So it is some air going through there or
everything is going through a stack?
MR. LEVESQUE:
record.
The two main stacks that you saw are
176 ventilated mostly directly in Zone 2 and 3.
And the
building is designed such as Zone 3 is at the highest
negative pressure.
So the air naturally goes through to
Zone 3.
But we do have some small stacks in areas
that do not process radioactive material such as the area
that inserts the phosphorescent powder into the tubes.
There is no radioactive materials in those areas
whatsoever.
And there is fume hoods for individuals to
work on there while they are doing the coding process, as
we call it.
There is also fume hoods in the glass forming
area where the tubes are formed.
Again, there is no
radioactive material in that area.
And there is various
furnaces and air-conditioners throughout the facility in
the Zone 1 that are there.
If we take in an incoming package that has
a leak it, for the very few times that it has occurred, we
have a tritium and air monitor that is in the receiving
area.
And there could be a very small emission as a
result.
But I would say that those would be significant in
comparison to the emissions that we monitor over the course
of a week.
MEMBER TOLGYESI:
So you have spot checks
in the -- you have some checks on the exhaust even if it is
177 not coming from production area?
MR. LEVESQUE:
record.
We have those isolated exhausts.
Like I
said, the ventilation system in the offices and that, those
are monitored for tritium.
But there is no tritium being
processed for those.
THE PRESIDENT:
from Staff.
But I just want to hear
I think the intervenor and some other
intervenors mentioned unmonitored emissions.
Are there any unmonitored emissions from
this facility.
MR. BUHR:
Rob Buhr, for the record.
I am a licensing and compliance officer of
the SRB facility.
Like Stephane was alluding to earlier, I
think one of the only areas in the facility that are
unmonitored would be the shipping and receiving area.
So
there is a small probability that a source received from a
shipment could be leaking.
But they would catch that quite
quickly with their air monitor.
So that would be the only
area that has no ventilation.
THE PRESIDENT:
Thank you.
Ms Velshi, you want to add to this?
MR. LEVESQUE:
for the record.
Sorry.
Stephane Levesque,
178 I am sorry for the delay in giving you the
answer for the Well 24.
answer.
I wanted to give you a complete
Well 24 is not affected in any way.
What is affected though, and I just want
to make it clear, is we had two wells that were removed as
a result of the construction.
The CNSC Staff is aware of
those and it has been reported as well in our compliance
report.
As Well No. 25 and 33, so those wells have been
removed as a result of the construction.
But Well 24 is
not affected in any way.
THE PRESIDENT:
Were they removed or
replaced?
MR. LEVESQUE:
altogether.
They were removed
They actually built on top of them.
THE PRESIDENT:
Any other questions?
So I have only one question.
I think the
intervenor questioned whether the 448 limit is still
adequate.
Staff?
MR. RINKER:
So the limit was established in the
previous licensing period as a means to ensure protection
of groundwater as a resource.
So that goal still remains,
and it is much lower than if we were to set a limit for
public protection such as a DRL.
So, yes, it is still valid regardless of
179 what their production is in an annual year.
THE PRESIDENT:
Dr. Hendrickson, you have
the final word here.
DR. HENDRICKSON:
Thank you, Mr.
President.
It is still clear to concerned citizens of
Renfrew County that the levels of groundwater
contamination, contamination of vegetation, air emissions
themselves, are at levels that do provide concern to
members of the public.
There are also concerns about accidents,
particularly potential accidents associated with fire and
breakage of tubes and release of tritium in large amounts
in the facility.
These considerations have prompted us to
again suggest, as we did even before the facility opened,
that this is not the right location for a Class 1B nuclear
facility in such close proximity to businesses and
residences.
I have talked to Mr. Robert Walker at the
Canadian Nuclear Laboratories about the possibility of
locating SRB at a place where there is an exclusion zone,
where there are guards to prevent many security issues that
might be associated with the depleted uranium or tritium.
And I would urge the Commission and SRB to
180 look into the possibility of relocating the facility to a
more suitable location.
Thank you.
THE PRESIDENT:
Thank you.
We need to move on.
And the next
submission is an oral presentation by Prevent Cancer Now,
as outlined in CMD-15-H5.7.
I understand that Dr. Sears will make the
presentation.
Over to you.
CMD 15-H5.7
Oral presentation by Prevent Cancer Now
DR. SEARS:
I am Meg Sears, I am an adjunct
investigator with the Children's Hospital of Eastern
Ontario Research Institute, and specializing in
environmental health.
I was originally trained in chemical
engineering actually, but now for the last -- over a
decade.
I have been working in epidemiology, toxicology,
and I have had diverse experiences in environmental issues.
I also co-chair a civil society
organization called Prevent Cancer Now.
And Prevent Cancer
Now has made previous submissions to this panel regarding
SRB.
181 So without repeating the kinds of things
that you are hearing from other groups, I am trying to fill
in how I may assist you with my expertise, both in the
epidemiology end of it and data, because one of my big
interests is data, particularly in epidemiology, but also
in environmental monitoring.
So I am going to speak to two issues.
first is low-dose effects.
The
And it is very true that if you
are not stressed with anything else and you have a small
stress as a result of some kind of environmental
contaminant or insult, that your body responds.
I have had CHR funding and looked at toxic
metals.
If you are dosed with a very small amount of
cadmium, then your body responds by producing the protein
that it needs to kind of wrap up that cadmium and take it
out of your body.
And there are good effects seen that are
associated with these physiological responses.
Your body
is pretty smart, it tries to take care of you.
But, you know, everybody put up their hand
if you have no stresses in your life.
That is something
that you see in a lab, but that is not reality.
And it is
not a good approach to public policy.
So when it comes to radioactive exposures,
the assumption is made in public policy that, you know,
182 less is best.
And so the no threshold approach is a very
realistic approach and I don't think that there is any
reason to think that we should be taking any other approach
than that to really try to minimize exposure of the
citizens and of the environment to environmental
contaminants, particularly the tritium.
The second issue that I have has to do
with data quality.
And it was only today actually that I
found the second SRBT website where they actually do have
this data.
There is another website that really doesn't
have very much.
And but the luck of Google I guess I ran
into the wrong website to begin with.
But I have to definitely agree that having
downloadable data, that would be useful to a toxicologist
or somebody who wanted to do mapping or anything like that,
it would be very very helpful.
The PDF data doesn't have
all the numbers in it, and so on.
You can get your bank statement and your
telephone bill and everything else offline in downloadable
data csv format types of things.
So I don't think that
this should be a very big deal, but it would be extremely
helpful presumably to your staff as well as to the public
and I would think anybody else who was interested in
environmental research.
183 And that is something that I have been
looking at, is how you can mesh environmental data with
health data.
And so that is the other half of it, is do we
have good data on the kinds of outcomes that you might
expect in terms of health outcomes within this area?
And I gather that quite a while back there
was a presentation from Lynne saying there were some
concerns in this area with colorectal cancer.
haven't tracked down that data.
But I
It would be helpful to
have the urine data, for instance.
And if people have
wells that are impacted, then perhaps offer that as a
public service as well.
But this data, you know, worker data, you
know, there may be issues of confidentiality, but those can
be dealt with in terms of, you know, giving -- but you
can't just give averages or medians, you have to give an
indication of the spread of the data.
And the spread of the data is something
that really shows up when you look at both the well
monitoring the data and the vegetation data.
Because when
I examined that data, from one site, from one year, there
is tremendous dispersion of this data.
So one day there
will be a very high level, one day there will be a fairly
low level.
And as somebody who deals with data sets
184 and statistics, if you have a very small number of
measurements, but they are very broad, the chances of you
having picked up the highest one within this small number
of samples is actually pretty low.
So rather than saying,
oh well, you know, we took a bunch of samples.
was an outlier.
Well, that
No, that is a sign that you may be missing
something very important.
So I would really encourage you, as an
approach to environmental monitoring data, to look for red
flags as opposed to being kind of placated by saying, well,
that was a bad day, but generally we are all right.
Because maybe you must miss a lot of bad days.
know, we don't have that data.
We don't
The data quality for the
vegetation is very very poor.
And finally, the last thing I would say
about data is I would just remind you of what we said in
our submission, which was taken from page 47 of the SRB
submission, which is the groundwater tritium concentration
in residential wells contributing to public dose.
And,
yes, it did go down somewhat until about 2012, but that is
flat-lined.
We are not seeing improvements in the last few
years.
So to say that everything is fine, it is
getting better and better and better, the data is not
telling us it is getting better and better and better.
185 So keeping that in mind, I think that 10
years, seeing as how it is flat-lined, is probably too
long.
And it would be very good to readdress progress in
this area in the much nearer future than to wait for
another 10 years going out.
With that, I would -- well, Prevent Cancer
Now has also submitted other recommendations in terms of
worker and public education and making testing available to
citizens and we would support recommendations by others
regarding how this type of facility would be better in a
more isolated area.
I would be more than happy to take any
questions.
THE PRESIDENT:
Questions?
Thank you.
Dr. McEwan?
MEMBER McEWAN:
Dr. Sears, thank you.
I am sorry you didn't write a little bit
more, because I think I might be a little bit less agitated
by some of the things you have written, particularly in
light of your presentation.
You use the 20 Bq/L as if it is currently
policy, and it is not.
I think the policy is still 7,000.
So I think it is disingenuous to start using a non-policy
recommendation that has not been acted on as part of your
recommendation at this stage.
186 How many places in Canada would have water
at levels that were less than 20, do you know?
DR. SEARS:
My understanding is that
places in Canada that are not impacted with nuclear
facilities have levels that are at that.
DR. THOMPSON:
record.
We have provided through the course of the
tritium reports on our website, but also through several
public hearings, that if you look at tritium concentrations
in drinking water supply plants close to all the operating
nuclear power plants and in Pembroke and Ottawa and
anywhere where there's an impact from any facility that
releases tritium, all the drinking water levels are below
18 becquerels per litre generally.
The exception are in some wells around SRB
and that's why the CNSC took strong regulatory action.
None of the wells where the values are being monitored,
elevated levels are being seen, are being used for drinking
water purposes.
The residences are connected to the
Pembroke supply -- you know, yeah, the Pembroke water
supply.
And so there is one area where SRB is
providing drinking water is to an industrial facility close
187 to their site, but it is actually wrong to say that in
Ontario, around nuclear facilities, levels are above 20, it
is simply not true.
THE PRESIDENT:
drinking water in Pembroke?
What is the level of
What is the actual becquerel
per litre?
DR. THOMPSON:
record.
It's around the detection limit, it's around five
becquerels per litre and sometimes it's a little bit
higher, but it's essentially affected by the discharges
from Chalk River, but it's around five or seven.
THE PRESIDENT:
Thank you.
MEMBER McEWAN:
So, again, I think the way
you have written your recommendations is unhelpful and
certainly it's unhelpful in terms of public education.
And in particular, the second last bullet
on the one page where you're suggesting people relocate if
they want to start families.
I mean, I think that's an irresponsible
statement to make in a public hearing because you have no
evidence to support that or, if you have, you've not
presented it.
And would you make the same suggestion for
somebody who is living in Calgary where I suspect the
background radiation is comparable, or to somebody in the
188 U.K. who's living beside a large motorway where they will
be exposed to large amounts of pollutants?
So I'd be grateful if you could explain to
me what you mean by that?
DR. SEARS:
It's our understanding, and
some -- looking at the facility, that this facility is
actually quite close to some residences.
So that -- in
that context we were not -- we're certainly not saying
that, you know, Pembroke should be vacated or anything like
that, it's people living in very close proximity.
And for the record, Prevent Cancer Now and
certainly the World Health Organization has identified that
living in close proximity to motorways also is very bad for
child development, for lung development, for asthma, for
cancer, for intellectual development.
So certainly there are many instances
where somebody who is considering having a young -considering starting a family, certainly we would recommend
that they not live right beside a motorway or right beside
a facility like this.
And, you know, distance is your friend in
so many instances.
MEMBER McEWAN:
So do you have evidence
that the tritium levels in the housing development that is
what, about 250 yards away, are raised?
189 DR. SEARS:
There are instances where
there are -- well, certainly the groundwater level was
elevated, but also the data on the vegetation is very, very
scattered, but some is high which indicates that there are
sporadic at least instances where there are elevated
exposures and -THE PRESIDENT:
Is elevated equated to
danger to your health?
DR. SEARS:
If you assume that the no
threshold model is correct, then there's some kind of
elevated risk, but we can't quantify that, we don't have
data.
THE PRESIDENT:
Well, I thought on some of
the vegetation there are limits and, if I understand
correctly, those limits on vegetation around this area are
within limits.
Staff...?
DR. THOMPSON:
record.
So we have done extensive measurements.
So it's
not sporadic, there's been years of monitoring around SRBT,
not just for regulatory purposes, but for research purposes
as well.
We have a good understanding of the
historic contribution and the current contribution from
SRBT.
Taking into consideration the higher measured values
190 for OBT, HTO in a variety of food stuff, measurements in
air and drinking and well water, the doses to the most
exposed individuals are still in the order of
microsieverts.
Using the LNT to estimate a cancer risk
based on microsieverts is totally inappropriate, it's
unscientific.
And I agree the LNT has great value in terms
of setting regulatory limits and driving ALARA
minimization, whatever we call it, and pollution
prevention, it is an essential tool, but it is not a tool
to assess the number of cancers or the cancer risk for
individuals in these areas.
THE PRESIDENT:
Questions?
Monsieur
MEMBER HARVEY:
Just to come back to the
Harvey...?
presentation, my question is addressed to Mr. Levesque.
Is there any possibilities that extreme
data could not be collected by the way you're monitoring
the air releases or the groundwater?
MR. LEVESQUE:
record.
Do you mean the machine data that they were
working on?
MEMBER HARVEY:
No, I mean all the data
you presented, because the intervenor was saying that the
way you're monitoring the air or the groundwater or the
191 releases to the atmosphere, there is a possibility that
extreme data or very high data could not be collected.
MR. LEVESQUE:
No, I think that we've got
a very extensive monitoring program around Pembroke and
that we monitor more than enough to be able to determine
the dose to a member of the public.
I mean, we sampled four gardens very close
to the facility, the local market.
We have 40 air
monitoring stations throughout Pembroke.
We monitor milk
from local producers.
I think there's a lot of things that we do
to be able to accurately determine the maximum possible
dose to a member of the public, but I'm always open to
somebody's suggestion.
MEMBER HARVEY:
And the possibility to
miss something is very -MR. LEVESQUE:
anything, I don't think we are.
I don't think we're missing
I think we really have all
the inputs into calculating the public dose, worst possible
case, to a member of the public.
MEMBER HARVEY:
Can the staff just comment
on that.
DR. THOMPSON:
record.
I'll add one element and then I'll ask Mr.
McAllister to talk about the new requirement for SRB to
192 become compliant with one of the CSA standards.
A number of years ago in response to
concerns expressed by members of the public in Pembroke,
the CNSC had put an extensive air monitoring network
essentially extending from SRB for several kilometres in
all directions.
From that data we have a really good
understanding of, with differences in wind pattern at a
time when SRB was discharging quite a bit of tritium into
the atmosphere, the behaviour of tritium in the environment
and the dispersion.
That work was published in a peer review
journal where we did correlations between what was being
measured in the -- by the monitors we had established and
the releases and the correlations were quite good.
So there is a good understanding of
essentially the environment, the atmospheric environment
around SRBT to allow the establishment of the monitoring
program to take into consideration those site-specific
considerations.
And I'll pass the microphone to Mr.
McAllister.
MR. McALLISTER:
McAllister, for the record.
Thank you.
Andrew
And just to pick up, Mr.
Levesque talked about always open for continuous
193 improvement and part of that is, of course, how we regulate
that.
There was mention earlier by Mr. Ruiter
during the presentation about the CSA standards around
environmental monitoring, effluent monitoring and
environmental risk assessment and those, again, will be
opportunities to re-examine the monitoring programs in
place and to see if any improvements could be realized to
be in alignment with those standards.
THE PRESIDENT:
Ms Velshi...?
MEMBER VELSHI:
It's again tied in with
the produce monitoring results and the variability that the
intervenor talks about because I think there's some other
interventions later on that talk about maybe the 2014
results not being consistent with previous results.
And I don't know if you've got the 2014
results, but are they in line with what you show on page 12
of your CMD?
Page 12 of yours.
THE PRESIDENT:
CNSC?
MEMBER VELSHI:
Yes, the CNSC CMD, I'm
sorry, of the EA, the EA Information Report.
--- Pause
DR. THOMPSON:
record.
We are looking for -- so we do have the 2014
194 results from the CNSC Independent Monitoring Program.
In the meantime, I'll ask Dr. Mihok to
sort of explain some of the variability that has been
observed around the facility.
We had for an entire summer the University
of Ottawa do a research project on the SRBT facility and we
have almost continuous air monitoring data and data from
vegetables essentially that were grown in gardens.
So I'll ask Dr. Mihok to talk about this
and the significance in terms of essentially regulatory
monitoring for SRB.
DR. MIHOK:
Steve Mihok, an environmental
risk assessment specialist with the CNSC.
So in the sequence of events, over
probably the last 10 years there has been a lot of work on
produce, work done that I've been involved in personally in
2005, 2007, 2008, 2009.
So again, the take home message is, we do
have a good understanding of variability and whether
produce match air match soil match rain and so on.
And to sort of close the book on some of
the issues and, in particular, to improve our models so
that we, you know, essentially do better in the future to
predict with less intensive monitoring, we had a research
project that we funded through the University of Ottawa in
195 2012.
It was conducted 50 metres from the facility, so
essentially next door, and we monitored just about
everything and we're working essentially right now with the
IAEA MODARIA Project to see how models perform in
predicting the numbers that we got.
And again, the take home message from that
kind of very intensive monitoring on a weekly or daily
basis is that you will see about a factor of 10 variation
in any one sample that you get, so you should never read
too much into a small number of samples and whether one is
a potential outlier or not.
The averages, you know, for reasonable
statistical samples give you a good picture of what is
happening in the environment, and in the case of this
particularly intensive work at about 50 metres from the
facility, we really don't have, I would say, any surprises
at all; things are behaving the way we expected.
The
science is going to advance with the work that we've done,
but the levels that we see are exactly what we expected
from the sort of compliance information that SRBT has been
collecting for many years.
And I think, it's a little bit off topic,
but since I'm at the microphone, you know, one of the
questions earlier was, does the air monitoring data sort of
make sense with the changes to the building and so on.
196 And we've done that kind of independent
verification of what happens very close to the facility in
terms of air concentrations getting essentially the same
numbers as SRB from their passive monitors, but using much
more sophisticated techniques and looking in a very great
deal of detail the differences between daytime and night
time, one week to the next and so on.
THE PRESIDENT:
Did you find the missing
data?
DR. THOMPSON:
Yes, we did.
THE PRESIDENT:
Go ahead.
DR. THOMPSON:
So I'll ask Ms Kiza Francis
to speak to the data.
MS FRANCIS:
Kiza Francis, I'm the Acting
Director of the Environmental Compliance and Laboratory
Services Division.
So I'll speak to the SRB data for 2014 for
the produce monitoring results.
I'm also going to tell you
a little bit about our Independent Environmental Monitoring
Program to help maybe give you another or a bigger picture.
So the 2014 produce monitoring results
gave an average of 135 becquerels per litre for their
produce; whereas 2013 was 91 and 2012 was 48.
In our Independent Environmental
Monitoring Program we had -- ours ranged from 19 becquerels
197 per litre to 180 becquerels per litre.
So their average
was within what our results were.
And so just to tell you a little bit more
about the Independent Environmental Monitoring Program,
it's a program that CNSC has put in place since 2012 where
we did a pilot at the Chalk River Laboratories and it's to
verify that the public -- independently verify that the
public health and environment around licensed nuclear
facilities are safe.
The IEMP is separate from but
complementary to our existing Compliance Verification
Program and it helps confirm that licensees' environmental
protection programs are working.
So CNSC staff take samples from public
areas around nuclear facilities, like parks, farmland,
homes, gardens, beaches and samples may be taken from the
air, water, soil, sediment, vegetation or some local food
like meat or vegetables.
In SRB's case we also sampled the
wine from the brew your own place beside the facility.
Some of the vegetation samples that we
took at SRB in 2013 and 2014 are kale, tomatoes, potatoes,
strawberries, carrots, zucchinis.
The samples are then
tested at CNSC state-of-the-art laboratory by qualified
CNSC scientists that analyze them using industry's best
practices.
We compare the measured contaminant levels to
198 applicable guidelines for measuring safe levels in the
environment, and we also compare to natural background
levels if we have that information, and we also compare to
a CNSC reference level and that's important to talk about
because the reference level has been determined -- it's
food specific.
So we look, based on the CSA N288.1
standard which tells us what the average Canadian consumes
in a year.
So, for example, the kale CNSC reference
level would be 104,000 becquerels per kilogram of fresh
weight; whereas our Independent Environmental Monitoring
Program showed that it was 180 becquerels per kilogram of
fresh weight beside the SRB facility, or near the SRB
facility.
So the reference level -- if you would
meet the reference level, you would receive a dose of .1
mSv per year.
So hopefully that puts a little bit in
perspective the result that SRB had of 135 for their
produce.
THE PRESIDENT:
Thank you.
Okay, anybody?
Okay.
Any last thoughts?
DR. SEARS:
I
199 greatly appreciate this opportunity.
And I would just finally point out that
the 2014 results that are on the SRB website indicate that
the range which I was talking about was -- you know, it's
not just the average that you have to be concerned about,
but the range was up -- well over 400 becquerels per litre,
so -- which you were talking about becquerels per kilogram,
it's reported in becquerels per litre, but the range is
from a few up to well over 400 that is reported.
So it is a very wide range that is being
detected and when you have that kind of variability, then a
few data points will never give you a fair representation
of what's happening.
If your entire reference level is
predicated on .1 mSv per annum, then, you know, naturally
you're going to end up with higher reference levels, but if
you want to compare with background levels, then you're
going to have to have more data.
THE PRESIDENT:
Okay, thank you.
Thank
you very much.
DR. SEARS:
THE PRESIDENT:
I think we're going to
break for -- take a little break here for about 10 minutes.
200 Suspension à 15 h 10
Reprise à 15 h 22
THE PRESIDENT:
Okay.
I'd like to
continue.
And we'll move to the next submission,
which is an oral presentation by the First Six Years as
outlined in CMD 15-H5.8 and H5.8A.
And I understand that
Mr. Castrilli will make the presentation.
Over to you, sir.
CMD 15-H5.8/15-H5.8A
Oral presentation by First Six Years
MR. CASTRILLI:
Thank you, Mr. President,
and Members of the Commission.
My name is Joe Castrilli.
I am a lawyer
with the Canadian Environmental Law Association in Toronto.
To my left is Dr. Ian Fairlie, a
consultant and expert from the United Kingdom who will
speak to the health effects or health risks of tritium
emissions from the SRB facility.
At the desk behind me is Dr. Hendrickson,
who's joined us again because he prepared a report on SRB
201 emission levels.
And we appear on behalf of First Six
Years, a group that's based here in Pembroke.
As a final person who's with us or who
will be with us in a moment, Ms Kelly O'Grady, who's the
President of First Six Years, who's also with us for this
particular presentation in case there are any questions
that are asked that are better answered by her.
We've prepared written submissions that
are before you.
In my case, I do not propose to speak to
mine any further than what is already in the written
material subject to any questions the Commission might have
of me, so at this point, I'm going to turn the microphone
over to Dr. Fairlie.
DR. FAIRLIE:
Mr. President and Commission
Members, thank you very much for this opportunity to speak
to you this afternoon.
I'm going to speaking about tritium.
It's
been the subject of my studies for at least 35, maybe 40
years.
It's a fascinating radionuclide, and,
unfortunately, it's also very hazardous, and also very
misunderstood.
Let's go have a few introductory comments
about how much tritium there is here at SRBT.
These are emissions from 2008 to 2014, but
202 before that, there were much larger emissions and which, in
fact, resulted in SRB's licence being revoked for a few
years.
These levels are very high in comparison
with, say, Darlington or with Dungeness in the UK and all
German nuclear power stations.
It gives you a range there
of the number of terabecquerels per annum.
And you can see that SRB is relatively
high, even although it's not a nuclear power station.
When the plant is in operation -- and
we've talked about air emissions in various models or so -this is the result of an IAEA modelling exercise showing
tritium exposures from inhalation of -- here one
terabecquerel was emitted over a one-hour period.
And you can see that the exposures are -come out -- from this power station happens to be Romania,
and the winds were coming from the southeast to the
northwest.
And you can see a plume.
And this is what happens, of course, here
at Pembroke.
This is looking at organically-bound tritium
doses from cow's milk and showing, again, a one terabec
emission where the wind is light and variable.
And you can
see the doses are much higher.
We look at tritium concentrations in air
near Canadian reactors, and this is -- the reason why I'm
203 putting this up it to show you the pattern of tritium
concentrations near a variety of nuclear generating
stations here in Canada.
The Y axis is logarithmic and the values
range from .01 to about 30, in other words, a range of
3,000, which is very high indeed.
Just for a matter of information, the only
figures that I could see for the tritium concentration here
at Pembroke was 12 becquerels.
And this fits in, if you
look to the extreme left, the sort of mauve blobs -- that's
from Pickering -- and you can see that it fits within
what's happening -- what has happened or what has been
measured at Pickering, also a very large tritium emitter.
However, we are really concerned to find
out how much tritium gets into foodstuffs.
And this
graphic -- by the way, the previous graph on this year
were, in fact, prepared for CNSC about 12 years ago by Dr.
Osborne and his colleagues.
I now have permission from him
to use those -- these graphs.
And you can see here that the closer you
get to the source of the emissions, the tritium
concentrations rise exponentially and we see very, very -some here are very, very high levels.
So what are the levels here in Pembroke?
Well, if you look at the third slide from
204 the right, you can see the range from about seven up to
over 200.
And this gives you -- this range here is
indicative of -- well, it's not very good data because that
is the only data that I've got that's been provided for by
CNSC or SRBT.
But they're enough to raise alarm bells, in
my mind.
You see, what would be a background level?
And the background level would be, say, for Lake Superior,
about three becquerels per -- per litre.
Lake Superior is chosen because (a) we've
got data for it, and (b) because it's not near any nuclear
or tritium-releasing facility.
So we can use two, three as being sort of
a background level.
In other words, tritium does occur
naturally in the environment from a number of sources.
In addition, if we also go on here to look
at sewage sludge from a recent document published by CNSC,
we can see that levels of tritiated water of 34 becquerels
per kilogram, but more interesting and more alarming, in
many ways, 400 becquerels of organically-bound tritium.
That means, to me, that the concentrations
of organically-bound tritium in people are higher than this
to produce, how shall I delicately put it, fecal in -- the
citizens of Pembroke to have such high levels of
organically-bound tritium means there are things going on
205 here which we really don't know about.
It means that the people are either eating
organically-bound tritium -- because these are very high,
almost 400 -- or they are making it themselves because we
all make organically-bound tritium.
In other words, the
lipids, carbohydrates and proteins in our body actually use
hydrogen from tritiated water to make organically-bound
tritium and new cells which are laid down also create
Alarm bells went off when I saw that
figure of 400.
It's only one figure, yes, it's true, but
it's -- there was a previous figure the year before of 290.
In other words, it's not going down, it's going up, if
anything.
I'd like to see a lot more
organically-bound tritium determinations made in people
near Pembroke.
You can do so with non-invasive bio assays
using fingernails or using hair clippings.
It's true that OBT determinations are
expensive and time consuming.
However, I think they should
be done.
Going on to the next slide.
People in Pembroke take in tritium by a
variety of methods, by eating foods contaminated with
tritium, by inhaling tritiated gas or tritiated water
206 vapour or by drinking tritium-contaminated water or by skin
absorption.
In fact, it turns out that inhaling
tritium and skin absorption are the two main methods of
getting tritium in people near -- who live in Pembroke.
I've made an estimation based on the
methodology of Richard Osborne of the annual intake values
of tritium near SRBT, in other words, within a couple of
kilometres.
As you can see, air inhalation and skin
absorption are by far the largest contributors, but there
is a little bit from food and water and drinks.
And I came out with a total of, roughly
speaking, two megabecs, or 200,000 becquerels per annum.
And this is -- I don't claim a great deal of accuracy for
this.
I'm using annual intake values from Health Canada
and I'm using the tritium -- environmental tritium
concentrations from the data that I've got from -- which
was provided by CNSC and SRBT.
But I think that it's the best estimate
that I can make.
I would say that it's roughly accurate,
at least to one significant figure, and I think that that
is probably going to be occurring as an average across the
whole of the 20,000 residents in Pembroke.
So just turning to tritium for a second,
the problem is that tritium has very low doses for -- per
207 becquerel.
It's one of the lowest of all radionuclides.
And the estimated tritium doses by the various sources are
very low, but if there's any error because of the huge
tritium releases, then the consequences could be severe.
I'm going to have to go on to -- there's
many, many official reports showing concern about tritium.
And what's wrong?
Basically, the wrong radiation weighting
factor, wrong metabolic models that are used, and a refusal
to acknowledge it's tritium.
My main conclusions are that tritium
concentrations in moisture, food and water, near SRBT are
high.
We've got high tritium exposures to nearby residents
which are likely to cause various levels of cancers and
leukemias, but they're hard to pick up.
And I make a
number of recommendations, which you can read for yourself.
Sorry I'm over the time.
THE PRESIDENT:
Questions?
Okay.
Thank you.
Who wants to start?
Dr. McEwan.
MEMBER McEWAN:
Dr. Fairlie, thank you for
the presentation.
I just need a little help with one slide
before I get onto the questions, the one where you discuss
key problem, which is towards the end.
DR. FAIRLIE:
Official dose per becquerel
208 for tritium is very low?
MEMBER McEWAN:
Yeah.
So that is the
absorbed dose per ingested -DR. FAIRLIE:
MEMBER McEWAN:
DR. FAIRLIE:
Becquerel.
-- becquerel.
Okay.
It's 1.8 times 10-11 sieverts
per becquerel, 10-11 sieverts per becquerel.
MEMBER McEWAN:
that it's very low?
Right.
Why do you say
Is that because of the organic bound
piece or -DR. FAIRLIE:
No, this is the official
figure.
MEMBER McEWAN:
No, no, no.
But why do
you say that it is very low and could be a mistake, which
is the implication -DR. FAIRLIE:
MEMBER McEWAN:
DR. FAIRLIE:
Yes.
-- of the third bullet?
Yes, that's right.
Basically because the official models used
assume -- make a number of assumptions which there -- we
don't really know.
For example, there's a very big assumption
that tritium is uniformly distributed in the body after
intake.
Well, we don't know that.
It could well be concentrated in various
209 organs or various tissues, and where it is, is extremely
important.
A tritium becquerel, for example, in your urine
sack wouldn't worry me very much, but if it's actually
located next to your DNA, wham, you start worrying.
So
location is -- well, distribution is very important.
And by the way, may I add, that's the
reason why I don't really use sieverts in my determination.
I use becquerels because we can actually measure
becquerels.
We've got a fairly good handle with it.
Dose, it all depends on where it is, so
it's tricky, so I don't really rely on dose.
MEMBER McEWAN:
I'm not sure I entirely
disagree with you on that, either.
DR. FAIRLIE:
MEMBER McEWAN:
DR. FAIRLIE:
MEMBER McEWAN:
You don't entirely disagree.
Yes.
Well, I'm glad to hear that.
So let me just come back
to this because, I mean, the whole -- that third bullet is
basically the thesis for your whole presentation.
DR. FAIRLIE:
Yes.
If we've got the --
our dose estimates -- our risk estimates, is a better way
of putting it -- wrong, then the consequences could be
quite serious.
MEMBER McEWAN:
So if -- let me ask you
the same question that I asked Dr. Ulsh this morning.
210 What are the data for the bio distribution
or for the binding of ingested tritium?
in the literature.
There must be data
I should have checked, but I --
DR. FAIRLIE:
Well, I -- in fact, the
reason why you didn't find it is because it's not on the
web, it's so old.
It goes back to the -- God, Pinsamt and
Langham is 1958, and other studies in the late sixties,
early seventies.
They're the only human data that we've
got, and they're -- hand on heart, for me to say that data
is absolutely correct is wrong because those were early
days and tritium detection techniques have improved
markedly since then.
But the data show that different organs
pick up tritium at different concentrations, and there's no
rhyme nor reason nor pattern except for this, that organs
which have high metabolic rates, for example, liver and
kidneys, seem to pick it up a lot.
And also, high -- organ cells which
reproduce very rapidly also pick it up, for example,
hair -- hair cells.
And also bone marrow cells pick it up.
And that's to be expected because there's a lot of cells
generation going on.
So apart from those rough and ready
general pointers, I can't really point you to anything
211 more.
However, I'm more than willing to enter into
correspondence with you and show you some of my older data
and the -- the older references which I have got.
I'm
certainly willing to do that, yes.
MEMBER McEWAN:
Okay.
So if we go to your
sludge data -DR. FAIRLIE:
MEMBER McEWAN:
DR. FAIRLIE:
MEMBER McEWAN:
Yes.
-- your sludge data -It's not mine, by the way.
Well, the sludge data that
you used in your presentation.
DR. FAIRLIE:
MEMBER McEWAN:
M'hmm.
You -- am I right in
thinking that you have assumed that all of the tritium in
the sludge comes from excreta and not from the water being
used to treat the excreta?
That was the implication of
what you said.
MR. LEVESQUE:
determinations of the excreta.
They made two
One was of the water -- for
the tritium in the water, and one of the fecal cakes.
Yes.
That was of -- organically-bound tritium
was in the fecal cakes -- dried fecal cakes.
MEMBER McEWAN:
DR. FAIRLIE:
staff?
Staff?
Sorry.
Did you just say
212 MEMBER McEWAN:
Staff.
Sorry, I just
want -DR. FAIRLIE:
I beg your pardon.
MEMBER McEWAN:
There was agitation behind
THE PRESIDENT:
Go ahead.
you, so.
DR. THOMPSON:
record.
Dr. Nana Kwamena will speak to the results
of the sludge measurements that were done, but one thing we
can definitely say is sludge is not fecal cake.
definitely not fecal cake.
It is
It has nothing to do with fecal
cake.
But I'll let Dr. Kwamena speak.
DR. KWAMENA:
So Dr. Nana Kwamena, for the
record, an environmental risk assessment officer.
So as Dr. Thompson has said, it is not the
fecal matter.
Basically, when the sludge arrives at the
treating facility, there are different processes that can
be used to process the sewage that comes in.
And so when the water is extracted, you
get the liquid effluent, which is the numbers that are
provided on the slide, as you can see, the HTO in
becquerels per litre, but then you also get a more solid
portion.
And that's what we measured the OBT levels in.
213 And so it's not a representation of just the fecal matter
that gets processed through the facility.
MEMBER McEWAN:
So simplistically because
I'm struggling with this, in -- so the organically-bound
tritium is made up of what?
DR. FAIRLIE:
Good question.
Normally,
municipal sewage is made up of fecal matter.
I mean, sorry, maybe I'm being too
simplistic here and I'm missing something very obvious.
However, when -- I would like to find out from CNSC what
exactly is in this sludge.
What is it?
I can't think of anything that SRBT would
be discharging which -- apart from fecal matter in the -in the sewage sludge.
It's -- I don't know.
MEMBER McEWAN:
It does seem simplistic to
me that it's just -DR. FAIRLIE:
My analysis is --
MEMBER McEWAN:
DR. FAIRLIE:
Yes.
-- simplistic?
Well, perhaps.
I think that if you were
to ask most people what's in domestic -- in municipal
sewage, they would tell you output -- human output.
And
perhaps my assumption of that -- I could very easily be
shown wrong, but what I've heard so far doesn't really
convince me one way or the other.
214 DR. THOMPSON:
record.
So just to put things in perspective, the
sewage from, you know, essentially residential and
elsewhere does contain fecal matter.
about it.
There's no doubt
But once it gets to a sewage treatment plant,
there are aerobic and other processes that will decompose
the material and, essentially, you get a slurry that is
then solidified and disposed of in various means, so the
measurements are on the solid portion.
To essentially take the measurement of 400
becquerels per kilogram, for example, in sludge and say
that this is equivalent to the quantity of
organically-bound tritium in an individual is, I think, an
overly simplistic information.
The -- there is essentially lots and lots
and lots of data, and I'll ask Mr. Bert Thériault to come
to the microphone.
There is extensive data that have been
used to develop metabolic models that represent tritium
intake, the formation of organically -- of organic matter,
lipids, carbohydrates and proteins with tritium that become
Those metabolic processes are
taken into consideration in calculating the doses and
coming up with the proportion of organic matter in a human
215 body.
That information has been used, is being
used and is represented in the dose conversion factors, and
so to say that, you know, only the big number of becquerels
intake in -- you know, the 200,000 becquerel intake per
annum is the only measurement that matters is wrong.
Really, what matters is the health effect
and the potential -- the association between the intake and
the health effect.
And we know that it takes orders of
magnitude more tritium to cause any health effects, and
even in some of the epidemiological studies that have been
done, for example, when we talked this morning about the
study on 42,000 workers where they were exposed to tritium
for years at much, much higher levels, we see no incidence
of cancer.
And to that say, you know, we don't know what
happens to tritium, we don't know how to deal with it and
we don't know the health effects of tritium is simply
wrong.
But I'll ask Mr. Thériault to talk about
the metabolic aspects of tritium and how we take into
consideration OBT and what the fraction of OBT is in the
human body.
MR. THÉRIAULT:
Thank you.
This is
Bertrand Thériault, for the record.
So in terms of the dose coefficient for
216 tritium, so just to be clear, these are factors published
by the ICRP that represent the dose received by a person
inhaling or ingesting one becquerel of a given
radionuclide, so they're tabulated for many different
radionuclides.
They're tabulated for different age groups,
for tritiated water, tritium gas, OBT as well.
For -- so for the intake of tritiated
water in a biological half-time -- half-life, so the time
to -- for the tritium to be removed from the body,
tritiated water, is roughly 10 days, and it's based on a
large amount of human data.
For organically-bound tritium,
it's taken to be 40 days, so a longer time.
Now, there are a couple of studies I'd
like to draw your attention to.
The first one has been
published by Dr. John Harrison and colleagues in 2002 in
the Journal of -- Radiation Protection Dosimetry Journal.
And what they looked at is they considered
the parameters that are inputs into the dose coefficients
for tritium and they looked at the variability of the data.
They looked at the range, the variability in the half -the biological half-life of tritiated water,
organically-bound tritium, the RBE from one to 2.5, and
they ended up with a range of dose coefficients for
tritiated water and for OBT.
And what we did is we applied the range
217 that Dr. Harrison had obtained to SRBT's 2014 data for the
dose, and we found that if we took the upper range that the
dose coefficients, considering the variability in the
biological half-life of OBT, varying it from 20 to 200
days, for instance varying treated water half-life from
five to 20 days, RBE from 1 to 2.5, taking the upper bounds
of those coefficients, applying to SRBT data we found that
the dose for 2014 went from .007 milliSieverts, which we
saw earlier today, up 2.02 milliSieverts,
So perhaps it
gives some context.
The other study is by Dr. Leggett and
colleagues.
We have the reference here.
What they did is
they compared the reliability of those coefficients for a
number of different radionuclides based on the amount and
type of data that was available to develop the biokinetic
models for these radionuclides.
They included tritium,
cesium-137, other radionuclides which are less common such
as antimony-125, ruthenium-106.
And they found that for
tritium they classified it as a Category 1.
So the more
reliable coefficient, the less uncertainty for tritiated
water and the moderate to high reliability for OBT.
So
perhaps this gives some context.
Thank you.
THE PRESIDENT:
DR. FAIRLIE:
Go ahead.
Thank you.
Ian Fairlie, for
218 the record.
For five years, from 2000 to 2005, I was
the scientific Secretary of the U.K. government committee
looking into precisely this.
It was an exciting time,
there were a range of views expressed, as you can imagine.
We looked specifically at tritium and the committee
couldn't agree.
There were about five on each side, five
who said we really have to look at this matter much more
seriously and five who said no, everything is fine.
had to agree to disagree.
So we
And that's exactly where we are
now here.
Myself, I was persuaded that there were
large uncertainties with tritium, larger than the ones
mentioned by Leggett or Harrison, as mentioned by the CNSC
staffer.
I would say that we should apply -- in the
face of that uncertainty or difference of views that we
should apply the precautionary principle.
thing.
It's the best
If we are not sure, let's err on the side of
caution, because essentially the duty of the Commission is
to protect the health of Canadians.
My understanding is
that, and that means that I think we should look carefully
at this matter and you know, say, well, we might be wrong
here.
In particular, both of the people cited
219 mentioned doses and I think that dose estimations are
highly unreliable, particularly for tritium, and I would
rather go looking at a range of other things to get a
handle on how to approach tritium.
If I may, Mr. President, with your
permission, there is a slide further on which perhaps
explains this.
I had to rush through.
Can I show this
slide about what I was wanting to talk about?
THE PRESIDENT:
May I?
You can show it.
read whatever you submitted to us.
We have
It was read very
carefully.
DR. FAIRLIE:
Of course, right.
I'm just
trying to -- right.
The reason why I think that the doses from
tritium are wrong are threefold here.
Because we apply --
our officials apply the wrong radiation weighting factor,
which is, in loose terms, we talked about this, RBE,
relative biological effectiveness, earlier on.
At the
present moment we use one unity and this is an important
issue, because if we get it wrong on what the radiation
weighting factor is, then it has important implications.
The United Kingdom's Advisory Group on
Ionizing Radiation, it is the premier group in the U.K.,
which I advised and we had a joint report, says that we
should really use a weighting factor of two.
The United
220 States, back in 2008, recommended a weighting factor of
2.5.
However, the ICRP said it wasn't going to
change from unity.
And I can tell you that the reason for
that is because the French government and its
representatives on ICRP said no.
No.
Because they had a
prize industrial application, a fusion research reactor,
ITER in Cadarache and it puts out very large amounts of
tritium, not petabecquerels, exa-becquerels in their
estimate, and doubling the dosage from tritium would
prohibit its construction.
But it's not -- and if you look at the RV
values, and these are all different experiments, 1 to 23,
and this is the best evidence that I can give to you, the
panel, and these are in vivo studies, live animal studies,
rats or mice in most cases.
They are not in vitro.
They are not cell studies.
These are in vivo studies.
This
histogram shows you that if you line them up in their
ascending order you can see that over on the left the
RBE -- these are the experimental results of RBE.
There
isn't a single one which shows you a value of one.
The
lowest is 1.3.
And if you rank them and put them up, you
will see the highest is about 3.4.
And this -- so we have
got 23 experiments here which all show high values from
RBEs.
That's pretty good evidence
221 MEMBER McEWAN:
that's justified by -- sorry.
Can I just ask you if
Can I just ask if these are
stratified by whether it's Auger emission or in vitro
emission?
DR. FAIRLIE:
MEMBER McEWAN:
DR. FAIRLIE:
MEMBER McEWAN:
No, these are tritium HTO.
This is all HTO?
All HTO.
Because that's not
actually what you say in the -- I mean you imply that
that's a mixture of Auger emissions and low -
DR. FAIRLIE:
No, no.
This is from my
article that I wrote.
MEMBER McEWAN:
DR. FAIRLIE:
Okay.
And my article was titled
"RBE and wR for Auger Emitters in Low Range", but these
experiments are HTO.
MEMBER McEWAN:
DR. FAIRLIE:
Yes, okay.
It's good that you brought
it up, however my article does go on to Auger emitters,
mainly because the Cherry committee that I was on spent a
lot of time on Auger emitters and tritium, as you know, has
the same problems as Augers.
THE PRESIDENT:
Look, as interesting as
all this debate is between you two -
DR. FAIRLIE:
Sorry.
222 THE PRESIDENT:
-- just for the record,
you cannot do it while we deliberate, but after we render
our decision you two can bond for as long as you want.
DR. FAIRLIE:
I beg your pardon.
You have
my humblest apologies.
THE PRESIDENT:
However, we have to bring
it down to something practical.
DR. FAIRLIE:
THE PRESIDENT:
Okay.
As regulators we are bound
by some international convention and that includes dosage.
And if I understood the argument, even on RBE applied to
these low levels of tritium, the levels are so low that it
is protected.
Somebody correct me if I'm wrong.
DR. FAIRLIE:
Okay, that's very true.
May I go back a couple of -- with your
permission, Mr. President, I would like to go back a couple
of slides and show you that it was one of three things.
It's the wrong radiation weighting factor, but there are
two other things which are wrong as well.
Do I have your permission to very briefly
discuss those?
THE PRESIDENT:
Very briefly because we
have -
DR. FAIRLIE:
sentences.
Very briefly, okay.
Two
223 When you have about, say, a Becquerel of
tritium inside you, you have to convert that to some sort
of -- well, what's the official dose -- to a dose
and
that's where you use metabolic or some people call it
dosimetric models and these models can be very wrong.
There are studies which I could send you which shows
uncertainty ranges from 200 to 20,000 in metabolic models.
It all depends on which data and which studies you use for
modelling the output or the excretion rates of tritium.
The previous evidence is that there is a half-life of 10
days for water, for tritiated water.
I would go along with
that, but when it comes to OBT it's much more tricky.
There are three excretion equations which
can be applied showing excretions lasting -- or half-lives,
biological half-lives going out to three or four years for
the long-lived components.
So there is a lot of
uncertainty when it comes to the dosimetric models.
I'm sorry, that's more than one sentence.
The third is that tritium has a lot of
very strange properties.
I have not been able to discuss
them, but following the slides the ability of tritium to
jump from molecule to molecule within a 10 to the -15/2,
i.e. exchange reactions, is incredible.
mind.
It boggles the
You say, “Well, why does tritium do this?” because
hydrogen is the lightest atom and so it's much more
224 swappable than the heavier items.
But it means that
tritium gets everywhere and it is not taken into account.
THE PRESIDENT:
But the bottom line still
is health of the population.
DR. FAIRLIE:
Yes.
THE PRESIDENT:
You know, I don't care how
it goes, your hypothesis is that it is unsafe.
If I
understand correctly, you listed Pickering as a high
emitter and presumably it has been running now for 30
years.
We should see some significant impact on the
population.
We see none.
That's the presentation that we
get here.
So how do you square -- so first to you,
how do you square that and, staff, how do we bring it down
to something that we can use as a regulator?
DR. FAIRLIE:
Is that question to me or to
the staff?
THE PRESIDENT:
DR. FAIRLIE:
May I go first?
THE PRESIDENT:
DR. FAIRLIE:
Both of you.
Go ahead.
Thank you.
There are some
epidemiological studies -- I beg your pardon -- near in
Canadian facilities.
They are not very good.
Some of them
only borderline statistical significance, others don't have
any statistical significance.
In my formal written
225 submission I say that we should not -- we should lower our
expectations when it comes to what we can get out of epi
studies.
They are not a very good true for digging the
truth, unfortunately.
I wish they were, but they are not.
What you need to do is look at really big
studies which have high levels of statistical significance,
where the protocols used in the epi studies are very good,
which are case control studies rather than ecological.
When you do look at those -- they are not in Canada; they
are in other countries -- we seek different patterns
emerge.
We see large incidences, for example, of childhood
leukaemia near all German nuclear power stations.
This is a German government study.
called the KiKK study, K-i-K-K.
It's
I recommended to you,
because if that is going on in Germany where the tritium
exposures are quite low, what's going on here?
THE PRESIDENT:
We have been presented
with a finding of this study at least half a dozen times.
So staff, can you bring your latest
understanding of that particular study?
DR. THOMPSON:
record
A lot of the information that Dr. Fairlie
presents in terms of the RBE, the metabolic differences,
the CNSC in one of our reports, the report on health
226 presents all of that information and we do make statements
that our understanding is the RBE is probably between two
and three.
That is one of the reasons, as Mr. Thériault
explained a few minutes ago that we do sensitivity analysis
and we do use those numbers when appropriate and when we
looked at the range of metabolic factors, the range of RBE,
including a high RBE factor for the people around the
Pembroke facility, the doses are still low.
But to bring things back to protection of
health, Dr. Fairlie is right in terms of we should not just
be looking at epidemiological studies.
That is why in the
tritium study report we looked at all of the evidence from
effects on cells, effects on organs, effects on whole
animals.
And so we looked at the weight of evidence from
the laboratory analysis as well as epidemiological studies
and all of that evidence indicates from laboratory studies
that it takes orders of magnitude higher than 200,000 Bq
per kilogram, Becquerel’s of intake to have any effect even
on cell cultures and on whole animals.
So using the weight
of evidence, it clearly does not support Dr. Fairlie's
position.
In terms of protection of health, we do
take this seriously.
We have done a number of studies and
we systematically look in every community where the CNSC
has facilities what the situation is.
227 So I will ask Ms Rachel Lane, the CNSC's
epidemiologist, to talk about in her discussions with the
Medical Officer of Health here what the situation is and
then perhaps she can talk about the findings of the RADICON
and other studies that have been done around the NPPs where
there is tritium exposures.
MS. LANE:
Rachel Lane, for the record.
I
am the CNSC's epidemiologist.
I actually spoke to the Renfrew County and
District Health Units’ Medical Officer of Health in
preparing for this presentation and she told me that they
are planning on updating their cancer report this year.
However, if you go to Public Health Ontario, it provides
updated data on cancer incidence by health unit in Ontario.
So I went to that website and I looked at the community.
Overall, all cancers, lung cancer and
breast cancer incidence in Renfrew County was similar to
the rest of Ontario and colorectal cancer was significantly
higher in Pembroke -- sorry, in Renfrew County, and
prostate cancer was significantly lower than the rest of
Ontario.
When speaking with the Medical Officer of Health,
she and I had the discussion of chronic diseases and
leading causes of -- leading factors that are related to
chronic diseases and the main risk factors for chronic
disease are unhealthy eating, physical inactivity, harmful
228 use of alcohol, tobacco use, and so on.
so one cannot --
so one has to take all of this into consideration when
looking at cancer rates in a community.
Now I would like to talk about the
epidemiological studies that have been conducted in Canada.
First of all, in Dr. Fairlie's submission, he stated
clearly that all of these studies were ecological studies
and commented on their blunt nature and then in his
presentation today he went on speaking about that cohort
studies and case controlled studies are far better
methodological designs.
This is correct.
There have been two cohort studies and two
case control studies looking at the health effects of
radiation among people living near or working in a nuclear
facility in Canada that have been conducted relatively
recently.
What's important in Canada is that we have CANDU
nuclear facilities, so tritium of course is a concern.
So
if one were to find effects one would expect to see likely
effects in Canada.
When we look at 42,000 nuclear energy
workers looking at their cancer mortality, from the 1950s
to the late 1999, we see no evidence that they have
increased risks of cancer due to their radiation exposure.
When we look at tritium specifically, it has no impact on
this relationship.
This is key.
229 Secondly, when we look at children living
around nuclear facilities, we looked at the nuclear
facilities in Ontario.
clusters.
We found no childhood leukaemia
Now, whether you use an RBE of one, two, 20 or
what have you, it basically comes to level and if you -- no
matter what the level of radiation that these people have
been exposed to in Canada, which we believe we know very
clearly, the bottom line is we do not see health effects.
We also have looked at case controlled
studies of people who had preterm -- sorry, parental
preconception exposure to radiation and specifically to
tritium.
In those case-controlled studies, the children of
those workers had no evidence of increased childhood
leukaemia or congenital abnormalities.
There have been
numerous ecological studies in communities near nuclear
facilities and there is no consistent evidence of any
reason to think that people living around nuclear
facilities are any different than other communities in
Ontario or in Canada.
Thank you.
THE PRESIDENT:
Just very quickly, does
that include the KiKK in Germany?
MS. LANE:
No.
KiKK is in Germany, not in
Canada.
However, there has been extensive work on
230 KiKK's study and it has been clearly stated among
international respected experts, the SSK, which was the
group that looked in detail at that study, and so on, that
it is very clear that the increased childhood cancer among
children 0 to 4 within 5 km of the nuclear facilities was
not due to the radiation emissions coming from the plant.
That study looked at distance, not doses.
There have been two studies that have
looked at doses rather than distance from a nuclear
facility and those two studies, one is in France and one is
in Canada, shows that the dose's distance is not a good
indicator of radiation exposure because of wind patterns
and eating habits, and so on and so forth.
not a good indicator of dose.
So distance is
Those two studies found no
relationship between radiation exposure among people living
near facilities and childhood cancer.
THE PRESIDENT:
move on.
Thank you.
We have to
Questions?
DR. FAIRLIE:
I would like to --
THE PRESIDENT:
You will get your chance.
Does anybody want to add anything else?
Go ahead.
MEMBER McEWAN:
So as I went through your
submission I went to some of your references and in one of
your references, the 2014 Journal Of Environmental
231 Radioactivity paper, hypothesis to explain childhood
cancers, you actually mentioned in that paper the 2011
Comare study in the U.K.
DR. FAIRLIE:
I'm sorry, the what?
MEMBER McEWAN:
The 2011 Comare study in
the U.K.
DR. FAIRLIE:
Comare study.
MEMBER McEWAN:
DR. FAIRLIE:
Yes, Comare, sorry.
I beg your pardon, yes.
MEMBER McEWAN:
That again suggested that
there was no association -- that the KiKK study was wrong
in that association.
So I was disappointed that in this
document you make the overt statement that the German study
is correct and none of the caveats that you discussed in
that manuscript that the German study may be wrong.
So I
was disappointed.
And I'm going to make two more comments
and then I will shut up, too.
The first is I make the same comment that
I made before, I think your recommendation eight on page 22
of your submission is irresponsible in the way it's
written.
I think that you are creating fear among the
population that is probably unjustified and you have
certainly written it in a way which I think is not
232 commensurate with our responsibilities.
The second thing is, I have some good
friends in the ICRP and I think they would be very offended
of your characterization in the document of it being a
self -- I can't remember what it was, a self- serving trade
organization.
DR. FAIRLIE:
Self appointed was the word.
I don't know where to begin here.
I will
go back now and I will deal with your first, if you don't
mind.
Ian Fairlie, for the record.
My recommendation that pregnant women and
women with young, very young families should consider
moving elsewhere was not made lightly.
I thought about it
long and hard and I know that obviously it would raise
concerns amongst families concerned, very much so; however,
it was based on very good evidence, in my view.
evidence.
Very good
In the sense that there are now over 60 studies
worldwide showing increased leukaemias amongst families who
live near nuclear power stations.
That's not one-six,
six-zero, and the best of which is still the KiKK study,
although there has been -- a number of governments have
tried to object to that.
So faced with the evidence that there are
raised increases of childhood leukaemias near facilities
233 putting out large amounts of tritium, a precautionary
approach is to say, look, you may want to think about this.
Not in a declamatory or inflammatory way at all, it's
basically saying this is what the scientific evidence
shows.
There's good evidence showing this and, therefore,
you may wish to consider it.
It's with a heavy heart that
I made that recommendation; however, I have -- my
scientific imprimatur on this was that the evidence was
strong enough to make that recommendation.
Now, the third point was your ICRP.
Well,
they are self-appointed.
What was the first one?
MEMBER McEWAN:
The COMARE study, that you
don't actually discuss –MR. FAIRLIE:
Oh, yes, the COMARE study.
MEMBER McEWAN:
MR. FAIRLIE:
yeah, right.
-- in a very lengthy --
In 2011, yes, in the U.K.,
That study was probably one of the worst
studies that I have ever seen in my life.
The government,
the Department of Health, had asked COMARE to do a study
which updated a previous study, with more recent data, and
they did it but at the last minute they yanked the more
recent data and said we couldn't present the data because
it was -- there were too many difficulties with it.
However, the press release accompanying the report talked
234 about the increased database, but it wasn't there.
Secondly, the study arbitrarily included non-Hodgkin
lymphoma as well as ALL into the study even though there
were no cases of it.
data.
So that meant the study diluted the
Now, these are no-nos when it comes to doing epi
studies; you shouldn't be doing that.
what you aim to do, do that.
You should set out
Instead what they did was
they looked at the data and said, no, no, no, no, we're
going to have to change it around a bit, and that is
unconscionable, it really is, and, therefore, that's why I
don't refer to it.
And, by the way, you may say, well,
where do you get these opinions from.
I got this opinion
from a number of people who were on COMARE and were ashamed
at the actual report that was had and they disassociated
themselves from it.
Now, to answer Dr. Lane's comments about
epi studies, the first study that she mentioned was worker
studies.
And everybody knows that there's a healthy worker
effect and I didn't include workers because it's such an
unreliable way of looking at effects.
You have to compare
workers with workers rather than workers with the general
population.
The other studies that she mentioned were
extremely poor methodologically speaking.
I don't really
count them as real case control studies because the method
235 for choosing the controls were not elucidated at all and
the number of controls were very small.
So, they were very
poor studies and I didn't rely on them in making my overall
conclusions.
here.
You may say, Ian, you're picking and choosing
But what does one do?
You have to look hard at the
various studies and figure out whether they are worth the
paper they're written on in many cases.
Now, you may say I -- you know, it's all
your personal opinion.
Perhaps.
I have given you the
evidence on which I base my opinions and I think the
evidence is very good.
I could go on to discuss a number
of reports which have validated the KiKK study, including
websites from the German Bundesministerium, which actually
back up with the KiKK study and explain to you why the
German Nuclear Control Commission didn't like the KiKK
study and said, no, they didn't like it.
I should say to
you that -- that one of the main reasons why the German
government has backed off nuclear power stations, and the
Swiss government and the Italian government, et cetera, is
because of the KiKK study.
THE PRESIDENT:
Okay.
Very quickly
because we've got to move on.
MS LANE:
The -- the healthy worker
effect, Dr. Fairlie is correct; however, the study that I
am referring to does look at dose response relationships
236 and that is only within the nuclear worker.
So when we
look at dose response relationships, we're only looking at
those with low doses within the group versus high doses,
and we found no relationship between dose or exposure and
cancer.
Secondly, the case control studies, what
you do is you look for cases, first of all, those newly
diagnosed.
national.
We use the Canadian Cancer Registry, which is
We also use the Congenital Abnormalities
Database, which is a national population control database.
We look at those cases and -- and controls and we see if
cases and controls have parents who had radiation exposure,
and we did not find that relationship.
The reason why
there were so few cases and so few controls was because
there were so few childhood leukaemias and so few
congenital abnormalities, so there was absolutely nothing
wrong with either one of those studies.
And then finally with respect to the KiKK
study and other studies that have looked at children living
around nuclear facilities, there has been a recent
workshop, and you may read the article by Laurier et al,
2014, that has looked at all of the studies of these
children and they have concluded that there is absolutely
no evidence suggesting that it's to do with the radiation
exposures; however, all of these experts do feel that the
237 understanding of childhood leukaemia is not well-known and
that there needs to be a more collaborative effort between
physicians, epidemiologists, biologists and so on to
understand the etiology of childhood leukaemia much better
so that we can address the childhood leukaemia issue
better.
Thank you.
THE PRESIDENT:
Okay.
Final word, sir.
Obviously we're not going to resolve -MR. FAIRLIE:
No.
THE PRESIDENT:
-- some differences here.
As a regulator, as you know, we have to listen to medical
authorities, international bodies, and this is not a place
to get a consensus.
Obviously it's a difficult issue.
We've got to listen to all the input and decide to follow
forward on it.
But you do have the last word here.
MR. FAIRLIE:
Okay, my last word.
Thank
you very much.
I agree with the dilemma you're in.
mean, I appreciate it, I really do.
I
And if there's any way
in which I can help more, I will.
There is a moral issue here that nobody
has talked about and there is an ethical dimension and to
me it's important.
We are -- we are deliberating whether
these tritium emissions should be allowed or not and -- or
licensed or not, and my heart goes out to pregnant women
238 and families with very, very young children.
worried about that, they really are.
They're
We know that embryos
and fetuses and infants are very highly radiosensitive and
we -- I think we should be doing our best to try and
protect them.
We know that tritium emissions float through
grade school and through children's classrooms.
should be trying to protect them.
I think we
We know that -- that the
people who work at these facilities, many of them are
youngsters and clearly teenagers from the photographs that
we see.
These kids shouldn't really be exposed to high
levels of tritium.
And there is -- what about the 20,000
people or so who live in the Township of Pembroke?
should really be thinking about them as well.
We
We're really
putting a blight on them.
So for those reasons, I think that we
should adopt the precautionary principle and we should look
long and hard at whether we give a licence to them.
Thank
you.
THE PRESIDENT:
Thank you.
The next submission is an oral
presentation from Ms. McNeill as outlined in CMD 15-H5.9
and 5.9A.
--- Pause
239 CMD 15-H5.9/15-H5.9A
Oral presentation by Ms Janet McNeill
MS McNEILL:
I always wind up going off
script a little and I guess I'm going to start right from
the to going off script.
I mean, I have this all written
and carefully timed it, five minutes.
Just off the top, if a person was at their
first CNSC hearing, something they would notice is that it
takes an awful lot of managers and complex management to
manage this supposedly non-problematic substance.
something you would notice right away.
That's
Okay, back to the
script -- script.
Good afternoon, CNSC commissioners and
staff, SRB personnel, members of the public, and all those
watching via webcast.
I do appreciate the opportunity to
speak to all of you at this public hearing.
As you know,
this is not the first time I have spoken at a CSC -- a CNSC
hearing.
In fact, II have done so several times now: in
Ottawa, in Curtis, in Port Hope, in Toronto.
My first
presentation to you, in fact, was the SRB hearing five
years ago, May 2010, in Ottawa.
Many people believe Albert Einstein
defined "insanity" as doing the same thing over and over
and expecting different results.
Sometimes I wonder about
240 myself appearing at hearings over and over apparently
expecting different results, yet never seeing them.
As it
happens, it actually wasn't Einstein who coined the phrase,
you can look that up, but he did say that using nuclear
energy is one hell of a way to boil water.
This is not a
non sequitur, since it is in the nuclear reactors in
Southern Ontario that Pembroke's problematic tritium
originates, a fact, I believe, not everyone in Pembroke is
aware of.
Full disclosure and no surprise to you,
Commissioners, I'm an antinuclear activist, though becoming
one took me by surprise and was definitely not part of any
plan on my part; it just kind of happened.
I have been
antinuclear ever since as a young university student I read
this book, Hiroshima, by John Hersey.
It was the tritium situation here in
Pembroke, however, that finally propelled me beyond being
quietly antinuclear into antinuclear activism.
I spent
more than six years living up in Renfrew County, in Deep
River mostly, and then some time in Pembroke.
I loved and
still love it up here and feel a strong loyalty and
connection to this area and to the people here.
Being aware that many people are
intimidated at the idea of speaking to a CNSC tribunal and
seemingly able to get past my own reluctance and fears
241 about doing so, I feel more or less obliged to take part,
as I know I am not just speaking for myself but also for
others who find they simply can't do this.
So it may be
insanity, but here I am.
As I appointed out to you previously, I do
not have a technical, scientific or mathematical mind.
I
am, on the other hand, very well attuned to language,
everything associated with language.
I have learned how to
dig and decipher my way through the language used by the
nuclear industry.
Many of us call it "nukespeak".
Over the past several years I have read a
lot of books that have informed me about the way the
nuclear industry operates.
I have a pile of them here.
There are some really well-told personal stories by people
who grew up in nuclear towns:
This one, Full Body Burden –
Growing Up in the Nuclear Shadow of Rocky Flats, is the
story of Kristen Iversen's experiences growing up in Rocky
Flats, Colorado, where nuclear weapons were being made in
such incredible secrecy most people in the community had no
idea what was going on, and where there were plutonium,
fires, spills, and also tritium inexplicably present and
never satisfactorily explained, as well as a lot of cancer.
Welcome to Shirley – a memoire from an
atomic town tells of Kelly McMasters' growing-up years in
another nuclear town, Shirley Long Island, where the
242 Brookhaven National Laboratory was leaking massive amounts
of tritium into the groundwater.
People were getting sick
with cancer and children were developing and dying from an
exceedingly rare brain cancer at frightening rates.
I also recommend This is my homeland –
Stories of the effects of nuclear industries by people of
the Serpent River First Nation and the north shore of Lake
Huron for a snapshot of the earlier piece of the nuclear
fuel chain, uranium mining, the Elliot -- the Elliot Lake
story.
Pat McNamara's book Port Hope – Canada's
Nuclear Wasteland is another, a book I know I mentioned to
you at the Port Hope hearing.
A story so mind-blowing I
still marvel at what I learnt about Canada's role in the
world's weapons trade and the cooperation of our
governments at all levels, municipal, provincial, and
federal, ever since the 1940s.
It shattered many illusions
I had held and, to tell you the truth, pretty much broke my
heart, and I'm not making that up.
Of course we all live downstream from
nuclear operations, even those who profit so hugely, but
Pembroke, with its elephant in the room, is
disproportionately affected.
Tritium and the SRB story:
enough understood by enough people.
Not well
Sometimes I wonder if
243 it's the GTE instead of the GTA, the Grand Tritium
Experiment.
Health impacts:
As part of my
supplementary submission I sent in a document that explains
the 1959 deal between the World Health Organization (WHO)
and the International Atomic Energy Agency (IAEA) in 1959.
I already said that.
IAEA is the global body that exists
paradoxically to both regulate and promote nuclear energy.
This 50-plus-year-old document lays out that WHO would need
to get IAEA's agreement on any research it wanted to do.
Why would the Nuclear Promotion Agency choose to support
research demonstrating the health impacts of nuclear
operations?
But, never mind, even without the
participation of WHO there is plenty of scientific research
available, proving that exposure to radioactivity harms
people, damages DNA, and sends its poisoned arrows into
generations to come.
Another of the presentations here
today has focused on health.
We just had it, so there's no
need for me to say any more about tritium and health
impacts here in Pembroke.
Regarding CNSC science:
I think it's
important for the people of Pembroke to understand that the
CNSC is not as scientific as it lays claim to being.
While
the language of the nuclear industry can at first appear
too technical for the average person to understand, one
244 learns pretty quickly that the CNSC staff's language is
actually often surprisingly full of unscientific claims and
conclusions.
Remember, I have been involved in a lot of
CNSC hearings by now.
I've heard the CNSC's Dr. Patsy Thompson
say, in an apparent attempt to dismiss the industry's
responsibility for exposing hundreds of workers at the
Bruce Plant to alpha radiation during refurbishment
activities in 2009, quote, "Bruce Power has a healthy
safety culture for the following reasons:
the alpha-event
was unforeseen for reasons that I don't have right now;
there was no evidence that there was a potential for this
event, so it's not something that Bruce Power or its
employees decided to ignore," end quotes.
reasoning appears to be:
Her line of
Since we did not think it would
happen and did not predict it or find it probable, we
cannot, therefore, be held responsible if it does.
In response to a question from the CNSC
Tribunal at the 2014 Pickering Hold Point hearing regarding
potential risk of a catastrophic accident at the Pickering
Nuclear Generating Station, CNSC staffer Dr. Rzentkowski
said, "... we can --" quotes, "... we can say the risk is
zero, because there was never a significant accident in the
CANDU fleet."
Really?
Okay.
This is a science-based prediction?
I'm going off script again here.
245 Spills and nuclear industry terms:
When you get used to
this stuff, spills are always said to be small; doses are
always very low; releases are always below regulatory
limits, and then there are DRLs.
I haven't time to speak
about the very unscientific concept of derived release
limits, but I did address it in my supplementary
submission.
DRLs are used to convey a false reassurance
that omissions are not a problem.
SRB's request for a 10 year licence:
find SRB's request to be unsupportable.
I
This company has
on innumerable occasions proven itself untrustworthy,
unreliable, dishonest, and has been guilty for 25 years of
blanketing the citizens of Pembroke with tritium via air,
groundwater, and releases to the public sewer system.
It
isn't safe for people here to eat the produce grown here
because of SRB's operations.
So, given that, can anyone in this room
really believe the company ought to be given a 10 year
licence?
A 10 year licence would vastly reduce the already
insufficient scrutiny of the company's activities.
We saw
what happened with SSI in Peterborough, 18 years of false
data and yet the endorsement of CNSC staff for a 10 year
licence.
There is a similar pattern here with SRB with 15
years of unreported -- underreported emissions.
Happily,
SSI has been shut down because of public pressure, I might
246 add.
Good news for Peterborough, bad news for the Pembroke
environment, with SRB having taken up SSI's slack.
SRB
needs/has always needed a shorter, tighter leash, not a
longer, looser one.
To conclude, I ask you to deny this
licence request.
I ask you to really listen to, digest,
and then act on the evidence presented here today as well
as that received by written submission, by organization and
individuals who have nothing to gain financially from SRB's
continued operations, but I don't really anticipate your
shutting down SRB, the CNSC is a licence-granting body.
I
have never known you to not grant the licence the proponent
was asking for.
I am aware that there is more to this
tritium and nuclear waste business than meets the eye.
believe there are big elephants in the room here.
I
So
instead of you asking to shut down this company, much as I
wish you would do so, I ask you -- I ask that you order SRB
to relocate to a place where there is a reasonable buffer
zone, so the Pembroke population and environment can be
protected from being subjected to any more years of tritium
emissions.
Pembroke does not need a tritium emissions
factory nor does it need a storage facility for nuclear
waste, and its nearby landfill site should not be used for
the dumping of nuclear waste either.
Since we know the
radioactive burden that already exists here is not going to
247 disappear magically overnight, the only solution is to stop
adding to it.
I've heard it said it's never the wrong time
to do the right thing.
I beseech you, please do the right
thing for the people of this community.
Twenty-five years
is long enough.
THE PRESIDENT:
Questions.
Thank you.
Mr. Harvey.
MEMBER HARVEY:
Yes, I would like to refer
to the written submission, the additional written
submission that's H5.9, the -- there's no pagination on
that, but it's about the release limit.
you can find that -- that page.
page.
No.
I don't know if
It looks like the first
There is -- at the beginning there is seven
pages -- or eight pages.
That's after that.
The -- I
would like the staff comments on -UNIDENTIFIED MALE SPEAKER:
THE PRESIDENT:
It's H5.9A.
Page 9.
If you go
down -- there is no page numbers, but if you go to section
B, derived limits, is that what we're seeing?
page.
MEMBER HARVEY:
Yes, that's right.
THE PRESIDENT:
"Derived Release Limits".
MEMBER HARVEY:
That's right, the first
It's -- at the beginning it's "... absurd release
limit for tritium".
I would like the comment -- the staff
comments mainly for the second paragraph, and, "When --"
248 the "'CNSC has currently set [derived limits] ...," it's
for SSI, but I would -- I would like to have the comments
even about that paragraph.
That one here.
MEMBER VELSHI:
It's this page.
MEMBER McEWAN:
It's this page and this
MEMBER HARVEY:
It starts "This is over
paragraph.
200 times higher than the total global natural tritium
production rate".
THE PRESIDENT:
MR. RINKER:
Yes.
THE PRESIDENT:
MR. RINKER:
You found it?
Okay.
So, we found it.
I can
provide a general answer, maybe not comparing it to the
global natural tritium production rate, but the limit here
at SRB was established not by the DRL model but more to
protect groundwater as a resource, and, in contrast, there
wasn't that same groundwater issue to the magnitude that we
observed at SRBT.
The licence limit, when SSI was
operating many years ago, was the traditional DRL-type
model of 1 milliSievert per annum was their licence -- was
the DRL for that -- for that facility.
MEMBER HARVEY:
But what about this --
this "over 200 times higher than the ... global"?
Is that
249 correct or it's ...
DR. THOMPSON:
record.
I would say it's really not relevant.
Like my understanding is this refers to tritium production
from cosmic reactions, and it's really not relevant in
terms of -MEMBER HARVEY:
Not relevant for the --
DR. THOMPSON:
-- regulating a facility.
What is important in terms of regulating a facility is
taking into consideration essentially the population around
the facility and making sure that there are controls in
place such that exposures remain below the appropriate
limits.
And in all cases -- and SSI I would agree
is an exception -- but in all cases the public has
continued to be protected from discharges to the
environment.
The release limit is one factor, but you know
there are action levels and administrative levels on
licences that essentially prevent discharges from reaching
the release limit.
And there's a reporting requirement
when an action level is exceeded.
And usually the action
level is set very much lower than the release limit.
MEMBER HARVEY:
like to comment to it?
Mrs. McNeill, would you
250 MS McNEILL:
Well, DRLs are a measure that
are used to reassure the public.
And I'm not reassured,
because what your staff has just said is that they're not
really relevant.
So this is a measure the industry uses,
and now the industry is dismissing it.
So this is the sort
of thing that, you know, I mean you just don't have any -it doesn't lend you credibility to say that, Well, it's
inconvenient for us to talk about this now, so we've got
something else going on.
DR. THOMPSON:
record.
What I said is that the limits are based
on one millisievert per year, taking into consideration
site-specific characteristics in terms of if there are
schools, residential areas, and other characteristics.
And
then we back-calculate, essentially, to make sure that
there is one millisievert to the most exposed critical
group in the area, and then we set a limit on emissions.
On top of that, there's regulatory controls in terms of
action levels and administrative levels to make sure that
the facility is controlled appropriately and the discharge
does not reach one millisievert per year.
MEMBER HARVEY:
So you didn't say that the
derived limit was not relevant, but the text -- the
comparison was not relevant.
251 DR. THOMPSON:
record.
That's correct.
What I said is that
comparing a release limit of one millisievert in terms of
how many becquerels of tritium it is to the global
production of tritium from cosmic reactions, for example,
is not especially useful or not relevant.
Thank you.
THE PRESIDENT:
Question, Ms Velshi?
MEMBER VELSHI:
I have a question for
staff on page 3 of the intervenor's submission.
There's talk of years and years of false
reporting of tritium emissions.
down.
It's the fourth paragraph
And I know we heard from SRBT this morning that even
when they had the high emissions they was still working
within their licence base.
Has there ever been issues of false
reporting deliberately by SRBT?
I'll ask staff and then
you can comment on it, Mr. Levesque.
MR. RINKER:
We're not aware of any false reporting.
I'm not sure where that information comes from.
report they were within their licence limits.
SRB did
When we did
some extra monitoring around 2006, when we realized there
252 was a groundwater issue, we tightened their limits very
tightly.
And they're still within those limits.
MEMBER VELSHI:
Maybe I'll ask Ms McNeill,
do you have evidence that would have led you to make that
statement?
MS McNEILL:
me.
Unfortunately it's not with
I gave the piece of paper to somebody else this
morning.
My understanding is that monitoring wells
were not being properly reported on.
Is that correct,
Kelly?
MS O'GRADY:
Missing.
MS McNEILL:
Missing?
MS O'GRADY:
They weren't in their
compliance reports.
MS MCNEILL:
Monitoring wells were missing
from ...
MEMBER VELSHI:
Missing is quite different
than false reporting ...
MS McNEILL:
Under-reported.
MS O'GRADY:
They didn't report that their
monitoring wells were built overtop.
It wasn't in their
compliance report.
It wasn't on their website.
in the staff CMD.
It wasn't mentioned anywhere.
It wasn't
You
actually had to drive to the site and see for yourself, and
253 you would have to know that there were monitoring wells in
that location and just put two and two together.
MEMBER VELSHI:
Mr. Levesque, comment on
that?
MR. LEVESQUE:
record.
I'm not understanding, because we've never
falsely reported any numbers or withheld any numbers from
the public or the CNSC.
accusation.
So I really don't understand the
And might I say that in addition to reporting
these numbers that we've had third parties come in and
verify our emissions to verify that they were in line with
what we had been reporting, and all those numbers were
successful.
MEMBER VELSHI:
And did that apply
pre-2008 as well?
MR. LEVESQUE: Stephane Levesque for the
record.
Yes.
MEMBER VELSHI:
Thank you.
THE PRESIDENT:
Anybody else?
Okay.
Any final comments?
MS McNEILL:
An analogy came to me this
morning, which was the company says, Well, you know, we've
cleaned up our act now, so you can trust us now.
The fact
254 is the reason the company has cleaned up its act is because
of the public pressure from my colleagues here in Pembroke.
And the company's been going for 25 years, so they seem to
be suggesting that because they behaved better in the last
five.
The analogy that came to me was an abusive
partner.
A women is, say, getting beat up by her husband,
and he keeps saying every time, I'm going to get better;
I'm going to get better; I'm going to get better.
times do you let the partner come back?
How many
You know, it's is
this really a trustworthy company, I guess, is my point.
Do you really feel you can trust them given the various
things that have gone on in the past.
THE PRESIDENT:
That's it.
Thank you.
I'd like to move on to the next
submission, which is -- sorry, I'm skipping here -- which
is an oral presentation from Ms O'Grady as outlined in CMD
15-H5.10, 5.10A, and 5.10B.
CMD 15-H5.10/15-H5.10A/15-H5.10B
Presentation from Kelly O'Grady
MS O'GRADY:
Good afternoon.
My name is Kelly O'Grady.
Pembroke.
I live in
And I want to thank the Commission for holding
255 the hearing here in Pembroke.
It's really important.
We
have people that are attending this hearing today that
normally wouldn't be able to go to Ottawa to see it.
So
it's a really good experience for them to see just exactly
how licences are decided upon.
I also wanted to thank Dr. Thompson for
doing the OBT-HDO ratio study.
I think that was really
important work that you did, and I'm glad to see that there
are some studies going on in Pembroke, because we are so
unique because of our very exceptional tritium levels in
human, in biota, in air, in water moisture, et cetera.
So my presentation is mainly going to look
at physical changes to SRB over the last 20 to 25 years.
So I'll just update this slide.
I'm going to be looking at
the differences between Zone 1, Zone 2, and Zone 3.
Because I don't think the public really understands and I
don't think I really understood until I actually got a full
copy of the 2007 systematic analysis of tritium sources.
Because the copy we got back in 2007 was redacted and it
had important diagrams on there that really do explain a
lot.
So Zone 1 is the waste storage area, to my
understanding.
Zone 2 is the waste packaging area.
Zone 3 is where waste processing was going on.
And
And by
"waste processing," I think that means that they were
256 actually crushing the glass, releasing the tritium, and
then having the glass go back to waste storage.
You may
correct me when you have a chance to speak.
MR. LEBLANC:
Excuse me, Ms O'Grady, are
you going to follow with the slides?
MS O'GRADY:
Oh, sorry.
MR. LEBLANC:
MS O'GRADY:
Okay.
Okay.
Thank you.
So SRB is one of three
tenants occupying the Butler Building located at 320
Boundary Road.
Harrington.
The building is owned by Michael
Michael Harrington recently applied for a
building permit for an expansion of 812 metres.
We're
curious about that.
We know that SRB occupies approximately 40
per cent of the building as is, and with the new addition,
we're not exactly sure how much that will change.
So the facility is divided into three
zones.
Each zone is determined by its potential for
tritium contamination due to handling procedures.
is according to the systematic analysis.
And this
Each zone has
ventilation systems specific for the type of work being
performed.
Yeah, so what we're looking at here at
this slide, this is the changes to the facility from 1990
to 2007.
There's three slides.
So if you can see, Zone 1
257 is the white area here.
Zone 1 is the administrative
office area, shipping, receiving.
Zone 2 is where they do
the silk screening and the painting.
3, this is the active area.
And then this is Zone
These are the stacks.
This is
a little garbage shed that was there, a little -- they used
to store their waste in.
You can also see that shipping
came to the front of the building during this time.
Total
square-foot area was 6,700 square feet.
So then between 1996 and 2001, SRB added
on another 3,000 square feet.
And that looks like it
mostly went to the Zone 1, but there was this little area
added on here to Zone 2.
right here.
So this is the new addition,
And if you want to compare with the year
before, you can see the difference.
it's 9,766 square feet.
So it expanded.
Now
You can see that they've added a
waste room here in the corner to Zone 3, but there is no
other changes to this zone.
Most of the changes are
expanding this area.
And then between 2001 and 2007, they
expanded Zone 1 again by another 3,000 square feet.
So you
can see this area right here is all new, built on.
That's
a lot of space for an administrative area, I think.
Now
the total space is 12,766 feet.
These areas are curious.
We're not
exactly sure what the ventilation system is for Zone 1 or
258 Zone 2.
It's not really discussed.
We found a document
showing the Zone 3 ventilation area.
that that's confidential information.
that.
Stephane tells us
And I disagree with
I think that should be public.
So if you look, there's the changes from
1996 to 2001.
So this is the new area, here.
And then in 2011, SRB dismantled this area
here.
So it's my understanding that there's nothing going
on right there.
There's a number of fume hoods in that
area, and there's fume hoods in this area as well.
During our tour, I asked Jamie where
the -- I asked Stephane as well -- where the actual
breakage occurred, the October 28th incident.
it happened right here in Zone 2.
So this is where the
breakage caused the alarms to go off.
is tritium exposures there.
monitoring.
that.
And he said
So definitely there
There should be some sort of
We've never seen any kind of reporting for
And that's the first time we've heard today that
there was actually another stack -- there was a third stack
at SRB.
New to us.
Okay.
So the other point is since the
birth of SRB, since its arrival in Pembroke, Zone 3, which
is their active processing area, has never expanded.
There
have been no changes except to add that one little storage
room to it -- a storage room which, by the way, isn't
259 sealed.
It has an open door to the outside.
convenient is that?
You can put your stored waste in
there, take the lid off.
stacks.
Sorry.
And how
It won't be monitored in your
I had to throw that in.
Okay.
So this is SRB's footprint.
They
claim to be adding another 180 square metres to Zone 1
again.
And again, I've already told you Zone 3 is the
smallest and it has remained relatively unchanged.
And so 815 square metres for the Michael
Harrington Butler Building actually translates to about
8,772 square metres [sic].
This is the floor plan that they give to
the public, and this is what they tell the public, that
this is where the expansion is going to go, this little
area right here, right in front of their shipping area.
It
makes me wonder how they're going to get their trucks in
there.
And there's really no driveway that comes in here.
It doesn't even look like a truck drives across the lawn,
because they'd have to go through Med-Eng over here to
travel down a little kind of a hill and get over here to
deliver their shipments.
It's a very curious set-up.
So there's issues around transparency.
have difficulty with this graph.
I
I think it's just done to
show the public that there's a downward trend.
There is
definitely an upward trend in the amount of tritium waste
260 that they're processing.
And they also claim that they did
no measures except maybe change the diameter of their
piping, yet their emissions have gone down to levels that
you would expect to see when they are not processing, which
is very curious as well.
And I haven't seen anybody
explain that satisfactorily.
And that again raises the question:
they actually monitoring releases?
questions, actually.
Are
It raises two
Are they actually processing?
they actually manufacturing lights in Zone 3?
Are
Because
that's where they would be manufacturing and that's where
you would expect to see at least 5,000, 6,000
gigabecquerels of tritium released from the rig stack
alone, not this number.
It just makes me curious why the
number is so low if they're still doing 400-and-some rigged
cycles per month.
The other thing is that we're concerned
about monitoring, whether they're actually capturing all
the tritium releases.
And we know that Zone 2 -- that's
where the accident occurred, that's where the alarm was
persistent, and that's where you had to actually carry the
damaged tubes that you were shipped into Zone 3 to let it
exhaust underneath the rig stack hood to the atmosphere.
So the stack ventilation system, that was
another point that we raised.
I thought that their
261 ventilation system, their bulk and their rig stack numbers
should be reported separately.
So I really am not in favour of a licence
for this facility, given that they are not disclosing their
true activities to the public.
It definitely seems to me
that they are a nuclear waste facility.
We've come across
invoices from the U.S. that show us that indicate that this
is SRB's main activity right now, and it is very
profitable, let's say.
The other concern is the licence
application guide, which tells licensees that they can
release solid waste under three tonnes per year per
building.
They can also release liquid waste per year
under the total amount per building.
So my question to the
Commission is, and to CNSC staff, is:
SRB is building on
another addition are they going to be allowed to have two
release limits?
Thank you.
THE PRESIDENT:
Thank you.
Questions?
MEMBER McEWAN:
Thank you for the
Mr. McEwan.
presentation.
And I must say, thank you for the plans.
used them a lot as I was reading it.
them.
Thank you.
I was grateful for
I
262 I'm still not sure what you're saying,
though.
Forgive me.
were saying.
I listened very carefully to what you
Did I hear you correctly that what you're
saying is that in fact they're not manufacturing signs, but
they're functioning as a waste facility?
Is that what --
that's what I think I heard you say.
MS O'GRADY:
It's what I'm putting
together, just like we had to put the well stuff together.
The emissions in Zone 3, which is their
active area, are not elevated at all.
non-processing.
They're like a
That's enough -- that's what you expect if
the equipment itself was off-gassing.
So either that and
the processing is going on in other areas of the facility
and they're not monitoring it, or they're monitoring it and
they're not reporting it -- that's the other explanation -or they've come up with some system of capturing the
tritium.
And they haven't.
containment system.
They don't have a secondary
They haven't done anything to their
processes since 2006.
They changed the diameter of
whatever tubing it was and whatever width it was, was it a
quarter-inch, was it three-quarter inch?
So yeah.
happening.
this.
Nobody knows.
That's what I think is
And the public really needs to be aware of
This is something, if it is happening, this should
be public information.
And this hearing should be a little
263 bit more elaborate.
There should be a very active
engagement with the public because of the changes to this
facility.
MEMBER McEWAN:
Staff?
THE PRESIDENT:
Let's start with this.
First of all, I want to ask a question in reaction to this,
and then I want to hear from staff whether it's possible to
hide emissions in this plant somewhere without it being
discovered.
Go ahead.
MR. LEVESQUE:
record.
And like I said, I'm a little
disappointed, because we in good faith actually gave an
hour-and-a-half plant tour to Ms O'Grady just recently in
March during work hours, and showed her the facility and
went through as much as we could.
And I been forthcoming
with all the information, including things like the
ventilation diagram which she refers to, which is actually
in her intervention.
I'm actually a little confused.
A lot of
the things that are in her supplementary submission and
presentation are falsehoods, and I can address them right
now.
264 Regarding the one you're speaking about
specifically, regarding the emissions from the facility,
there's a table in her presentation and statements that are
made that are releases from the waste room.
the main one:
monitored.
I'll address
releases from the waste room are not
But yet in the document that the floor plans
were taken from, which is the sources document, which is
dated March 29, 2007 --
and I know, because that's the
only document that we put the changes in the facility from
what it was to 2001, because it hasn't changed since 2001.
In this same document, it states that there are releases
from the waste room and that they're monitored.
clearly in black and white.
It says it
And again, there's the sources
document from March 29, 2007.
And that's the same for a number of other
things in the presentations.
And I can address them one at
a time, but no, the emissions regarding the waste room,
regarding the stub crusher fume hood, they're all
monitored.
And we actually discussed that during the plant
tour on March 16th.
So if somebody asked me, Are the
emissions from our facility monitored?
Yes, they are.
And
I think I mentioned, you already heard that if there's
something that comes in the facility -- a broken sign or
lights that are broken -- and there's some small emission
in Zone 1 while it's transported to Zone 3, there's a
265 possibility for a fraction of emissions to be resulting
from that.
But that's a very rare occurrence that that's
happened.
THE PRESIDENT:
So you mentioned some
false information in her presentation.
I mean, what are
the false information you're talking about?
MR. LEVESQUE:
THE PRESIDENT:
There's lots.
Lots.
Well, give me another one
or two.
MR. LEVESQUE:
waste facility.
Okay.
It is we are not a
We showed that during the tour.
The only
something that someone would define maybe as waste that we
take back is we take back, as I mentioned earlier, old
product that's expired.
And that only represents, like I
said, nine per cent of our revenue in 2014 and six per cent
so far in 2015.
So it's entirely false to say that.
We are processing in Zone 3.
We are not
doing any operations in Zone 1 that creates any significant
release of any sort.
totally misleading.
So that's entirely false and it's
And we actually went through this
during the plant tour with Ms O'Grady and Dr. Hendrickson.
Regarding wells that we're not reporting,
I also don't know what we're talking about.
can't speak to something I don't know.
I'm sorry, I
266 THE PRESIDENT:
Staff?
Can somebody hide
emissions?
MR. RINKER:
I will give a first answer and then pass
it back to Dr. Steve Mihok.
We do inspect and visit this facility.
is not a large facility.
It
You can look in every room and
every corner to understand where is the material and where
is the work that's being done.
So there isn't any
possibility for hidden material that could compose a
release.
And I will pass the question back to Dr.
Mihok.
DR. MIHOK:
Steve Mihok.
It's a bit of a jigsaw puzzle.
We have
all sorts of lines of evidence that tell us whether what is
being reported is factually correct.
We have air
monitoring, slow monitoring, precipitation monitoring,
stack monitoring, produce monitoring.
And one of the reasons corrective action
was taken many years ago was some of those numbers actually
didn't match and they didn't match because there was a
mistake essentially in the amount of tritium that was being
reported, relative to what was actually leaving the stack
and it was essentially a spreadsheet error.
It was one of
267 those annoying things that crept into the data.
Now, when some of these things came to
light many years ago we had various crosschecks on whether
or not fugitive emissions were occurring.
That was one of
the ways of understanding why things didn't match up and
one of the better ones was the roof runoff, so the times
when SRBT was not processing, and so on, what did the roof
runoff look like?
If there were large fugitive emissions
then there would be a lot of tritium in that water running
off the roof.
Well, there wasn't, so that was a very good
line of evidence.
We have done other studies on and off, but
the most important one is the one from 2012 when we worked
with the University of Ottawa to monitor the air on a very
fine scale.
So we have lots of data from that summer on
weekends and so on, when again we knew no processing was
going on and what we found in that study was essentially
that the levels of tritium in the air near the building are
very, very close to background.
So it's like the tap gets
turned off when SRBT is not operating.
So there are some fugitive emissions and
we have that data from 2007 when they weren't processing
tritium.
They were just handling it in light tubes.
We
have a very good understanding of those numbers and how
they contribute to the overall total.
268 So I just worked up those numbers
literally days ago, cross-comparing across years and
something on the order of maybe only about 10 percent or 20
percent at most represents other processes going on in the
facility when they aren't actually operating the rigs or
splitting the tritium, something like that.
THE PRESIDENT:
Questions?
Thank you.
Ms Velshi...?
MEMBER VELSHI:
Sir, there have been a
number of allegations they are becoming a dumping ground
for waste and you said 9 percent of your revenue comes from
the taking back of used light.
How much of your processing
volume is from that, your processing volume of tritium so,
you know, you're 30,000 terabecquerels or whatever?
How
much of that would be from these returned fix -MR. LEVESQUE:
record.
When we talk about processing we talk
about taking tritium from a bulk container and putting it
into a light source, so taking back an expired life source
doesn't count as part of processing whatsoever.
MEMBER VELSHI:
Okay.
So your actual
business volume has gone up of production rather than -- I
mean in addition to probably taking back.
Okay, thank you.
Mr. President, if I can ask another
269 question, unless someone else has one?
This is to staff.
The intervenor talks
about differences in U.S. requirements, regulations and
hours when it comes to these devices and inventory
management.
Can you explain what the differences are and
why and are we less rigid in hours and, if so, why?
MR. BUHR:
Rob Buhr, for the record.
In the United States all manufacturers or
distributors of radioactive signs are required to follow
the regulatory requirements and those are considered
general licensees.
However, they go on a little bit
further for people who purchase the signs.
They are called
specific licensees and they don't have a specific license,
but they are expected to follow certain rules around
handling these signs.
One of the main differences is that
these industries or people who purchase the signs have to
keep an inventory of how many signs they have in a building
and they have to account for where they go.
So if the sign
is sold or given to another facility, they have to account
for that and show tracking records of where that inventory
went.
In addition to that, there are also
requirements are around how they dispose of that sign, so
they are not allowed to send the signed directly to
landfill.
It is supposed to be disposed of in a proper
270 manner.
In Canada it's slightly different.
have kind of two thoughts on the waste.
We
So somebody like
SRB who manufactures the signs is under a license and
therefore they are required to dispose of it at a proper
disposal facility.
On top of that, they are also supposed
to provide like a procedure for how to dispose of the sign
properly when they sell the sign and give options on how to
retrieve the sign back after it is no longer useful.
So
SRB does this.
The second kind of waste option is when
SRB sells the sign, or any manufacturer's sells a sign in
Canada.
That person who purchases a sign, there is no
requirement on how to dispose of the sign so they are given
the option to return it to SRB or to a proper disposal
facility or they can dispose of it in the landfill.
Those
are the main differences between U.S. regulations and
Canadian regulations.
MEMBER VELSHI:
So from the way you have
described it, ours seem a bit more lax than the U.S. ones,
where if I were to get one of these lights I can go and
throw it in my local landfill site; correct?
MR. RINKER:
Yes, that is correct.
It is generally not homeowners who have
271 exit signs.
It is businesses who may have a number.
So
it's in their interest to send it back to SRB.
Nevertheless, some do end up in landfills
and there is no regulation that would require them to do
otherwise.
There is data about what are the tritium levels
around landfills.
We have had CNSC subject matter experts
look at that data in the U.S. and the U.K.
It is
generally -- leachate from landfills, I believe, is in the
order of hundreds to a couple of thousand Becquerels per
litre.
So there is certainly a signature of these things
in landfills, but there is a signature of many contaminants
that are together with that leachate.
MEMBER VELSHI:
So is the U.S. regulation
driven by landfill contamination a concern or is it
anything other than that?
MR. RINKER:
So we believe there was an issue some time
ago with Walmart that had many signs.
I think some were
unaccounted for, and it was that -- well, the NRC did not
have a concern -- I think there was on the order of 15,000
signs -- about the health consequences.
They felt maybe it
was prudent to put in a requirement to respond to public
interest, public concern, and also to deal with this issue.
THE PRESIDENT:
Walmart?
What happened to the
I remember there was an order to all equipment
272 older -- to report back in what was the end result?
MR. RINKER:
story.
So I don't know the complete
I know some of those signs were -- it was a company
called Isolite who took over control of those signs and at
the time Shield Source, who was also required to collect
signs, did retrieve some -- had the import license from
Isolite.
So they may have been returned in that case.
THE PRESIDENT:
So as the intervenor
argues that Isolite has some relationship with this RBT -in other words, did all this stuff come back to Canada?
MR. LEVESQUE:
record.
Thank you very much for the questions
because this is one of the things I was going to bring up
that's very important to me personally, is on page 3 of Ms
O'Grady's H5-10A, if you wouldn't mind bringing that up,
please?
I think in red it says:
"In retrospect, it is apparent that
SRBT was involved in some way with
the Walmart tritium light inventory
through their partnership with
Isolite.
SRBT..."
That would be me in this case:
"... should be held accountable for
misinforming the Commission and for
273 their lack of transparency."
I was asked those same questions back in
2008 and '10 and I stand on what I said then.
We did not
have at that time any knowledge of what happened to those
signs, nor do we today, nor did we have at that time any
relationship with Isolite.
Their relationship began after Shield
Source, who is a sister company of Isolite, started getting
into some issues with the monitoring of their emissions and
we had a meeting, I believe in January 2013, where we
discussed supplying them.
We supplied them samples in
February 2013, so several years after this happened.
So we
are actually not aware of what happened with the large
number of signs from Walmart, nor were we involved.
So we can't answer the question for you.
I'm sorry, I don't know if they came back to Canada. I have
no idea.
THE PRESIDENT:
Just so I understand what
Ms Velshi just asked, in the U.S. how do they dispose of
those signs nowadays?
MR. LEVESQUE:
record.
I know that we take back some signs and
apply for import permits, take back some signs from
customers in the U.S.
So that is a route.
274 I know there are other routes that they go
to waste brokers, none of which are sister companies of
hours.
We do know them because some of them come to us for
quotes to want to get rid of those signs, some of them have
other means of getting rid of them other than SRB
Technologies.
THE PRESIDENT:
But waste broker, it could
be a municipal waste?
MR. LEVESQUE:
There are private companies
out there that just handle various types of waste,
including tritium signs.
THE PRESIDENT:
I'm still trying to come
to grips with here you don't need any intermediary.
You
can go and throw it away in the local dump; is that
correct?
MR. LEVESQUE:
record.
Yes, an end user is allowed to throw it to
the dump, but we offer the service of taking it back.
THE PRESIDENT:
that in volumes?
So do you know if some do
Some users actually dispose of them in
municipal dumps?
MR. LEVESQUE:
record.
Not to my knowledge, no.
275 THE PRESIDENT:
Ms Velshi...?
MEMBER McEWAN:
So can I just be clear
that I understand?
For the expired signs you contract with
a company to take them back.
You bring them back to your
facility and you are really just acting as a transit point
to then go to Chalk River; is that correct?
MR. LEVESQUE:
record.
No, not exactly.
There is the case that
companies come to us to dispose of signs that are in their
possession, but there are also end-users that come to us to
get rid of signs for replacements.
And we just don't take
the signs and send them to waste disposal.
We take the
signs, we log them in our inventory, we assess whether
there are parts that can be reused.
In certain cases we reuse the entire sign
because it hasn't expired yet.
It's still well within the
luminosity required to meet building codes.
In certain cases we take the lights out
and we use them for totally different applications.
And, yes, in some cases we take the lights
out, repackage them and send them to AECL or another
licensed waste facility, but never to landfill.
MEMBER McEWAN:
Okay.
But you are not
actually processing the tritium in the signs?
276 MR. LEVESQUE:
record.
No, we are not.
That's an operation that
ceased when we went for our license as requested by the
members of the public.
MEMBER McEWAN:
So the complete light is
either reused or sent to Chalk River?
MR. LEVESQUE:
record.
Exactly.
MEMBER McEWAN:
Thank you.
MEMBER VELSHI:
I just want reassurance
from staff that we have actually assessed the potential
risk of us not monitoring what happens to these signs at
the end if they are not returned for disposal at a proper
facility.
DR. THOMPSON:
record.
So at the risk of getting Mr. Binder a
little bit upset I'm going to quote a document from the
AECB days.
So there is a regulatory document that was
created probably in the early nineties on exemption of
essentially fire detection and such equipment and that -essentially, that regulatory document did a number of
assessments looking at the health consequences of disposing
of fire alarms and light signs and things like that and the
277 assessment at the time was that those would be below -would be de minimus and de minimus was defined as 50
microSieverts.
And on that basis the regulatory document
allowed for disposal to landfill of essentially those
pieces of equipment on the basis that it would be unlikely
that several large numbers would be disposed of at the same
time.
On that basis, I know that a number of years ago
there were issues with OPG trying to send material to
Ontario landfills.
Essentially it was contaminated soils,
and there were some measurements of tritium in landfills
and then some discussions.
My recollection of that data is that the
concentrations were in the hundreds of Becquerels per litre
in certain landfills, but certainly not to the levels where
we would see a risk and, as was explained earlier, leachate
from landfills is handled then appropriately.
THE PRESIDENT:
So is there a number?
Is
there a number now that defines the release limit and
therefore you can do this under that particular release
limit?
DR. THOMPSON:
record.
My understanding is that individuals can dispose
of such things through regular garbage essentially to the
landfill, but for bulk material there is a requirement to
278 send the material to a CNSC licensed waste facility.
We
could come back perhaps -- I don't know if there is a
break -- with more details, I know it is in some of our
regulations in terms of the cut off, but I don't have that
number with me.
THE PRESIDENT:
Okay.
Thank you.
Go ahead, Monsieur Levesque.
information.
MR. LEVESQUE:
DR. THOMPSON:
Oh, we just have the
Sorry.
THE PRESIDENT:
MR. RINKER:
Go ahead.
It's in the Nuclear Substance
and Radiation Device Regulations.
"A person may dispose of a tritium
safety sign without a license as long
as it contains less than 925
gigabecquerels of tritium."
THE PRESIDENT:
that everybody follows this up?
differently.
So how do you make sure
Okay, let me ask it
When you put yesterday the sign originally,
what is it’s -- what level is it when it's new?
MR. LEVESQUE:
record.
For the signs produced for Canada, they
are below that tritium content of 925.
279 THE PRESIDENT:
are disposable?
So from the get-go they
Is that the way I can understand it?
MR. LEVESQUE:
record.
Yes.
THE PRESIDENT:
So if somebody wants to be
really malicious and accumulate them, then you get into a
different issue.
Can you?
Is it cumulative?
Can I buy
100 of those things and I am above my release limit?
MR. RINKER:
According to the regulation, one sign with
925 gigabecquerels of tritium activity can be disposed of
and if you had 10 of such signs you could dispose of them.
THE PRESIDENT:
I think the AECL document
requires review.
DR. THOMPSON:
record.
I know a number of years ago there was an
issue that there were some buildings being dismantled in
Winnipeg where a number of signs were disposed of with the
garbage and I know there was some review at this CNSC, or
AECB at the time, but my understanding is that when the
Regulations were updated it took into consideration the
potential outcome of disposing of signs when there are a
number of signs in industrial buildings.
280 THE PRESIDENT:
All right.
Okay.
Questions?
By all means, it is your turn
now.
MS O'GRADY:
Mr. Rinker made a comment
about SRB is a small building and you can't hide anything,
but I can show you the slides of the layout.
There is one
area of this building that we have never been through and
it's this area right here.
Zone 1.
It's never been on our tour.
We have maybe seen part of this area, but this has
never been -- Zone 1 has never been part of our tour.
And we have never actually seen inside the
waste room.
We understand it is high level waste in there,
so we were happy that you didn't actually open the door.
I'm a little bit worried when you say you can open the
other door but you don't because it's sealed.
My other comment is Mr. Levesque says that
he doesn't know exactly what happens to these lights, but
the U.S. does.
The USNRC really strictly regulates their
lights and in fact there is a mediatory.
They are called
Lampmaster and they give the client the packaging
instructions.
So you are only allowed to pack 10 lights
per box and if you pack eight and you pack 10 in another
and then two in another one you are going to be dinged $100
or $150.
It is $150 per light.
If you send SRB more lights than you told
281 them that you were going to send them, that's another fee
of $50 or $100.
If you send them a damaged light, they
have the right to send it back to you or refuse your order.
So they definitely have a very nice setup here, so if you
were to relook at that AECB document, I mean you are going
to be putting a little bit of a dinge into their very handy
little business.
I think I just wanted to ask Stephane.
When you say your waste lights go to a licensed waste
landfill, are you referring to yourself?
THE PRESIDENT:
MR. LEVESQUE:
Go ahead.
record.
No, we are referring to a CNSC licensed
waste facility, not SRB Technologies, typically CNL.
MS O'GRADY:
(Off microphone).
MR. LEVESQUE:
record.
Not ourselves included.
THE PRESIDENT:
Anything else?
talk about this top-secret little zone here.
But just
What are you
hiding in there?
MR. LEVESQUE:
record.
Thank you very much for the question.
This is one of the -- and if I can address
282 a couple of them you asked me and gave me the opportunity
at the falsehoods that I was talking about.
Ms O'Grady and Dr. Hendrickson actually
finished their tour in Zone 1.
If you look at the yellow,
right where you see the blue saying "Main Floor", just over
1,100 square feet, these were where all the offices were
where she met a number of staff, including our project
engineer here, Courtney Sinclair, and this is where the
tour ended.
So she saw that facility.
So I am baffled. I'm sorry but -THE PRESIDENT:
Is there any secured zone
that you wouldn't let the public in?
MR. LEVESQUE:
Absolutely none.
We showed
Dr. Hendrickson and Ms O'Grady everything.
Ms O'Grady, when she came to Zone 3, I
wanted to show her that we didn't store waste, because you
are looking at a room that is 7 x 6.
show you the waste room."
didn't want to.
I said, "And I will
I was going to open it, and she
And Dr. Hendrickson was okay with me
opening the room, so I did and showed it to him.
I believe
he is still here today.
And, you know, the tour was not just with
me.
It was with our Vice President, Ross Fitzpatrick.
Jamie MacDonald and Doug McNab joined us for part of the
tour and Courtney as well.
283 THE PRESIDENT:
It sounds to me like you
need to ask for another tour.
MS O'GRADY:
Yes.
THE PRESIDENT:
MS O'GRADY:
Right.
No.
THE PRESIDENT:
MR. LEVESQUE:
Anything else?
Thank you.
I'm sorry.
I just had a
couple of things quick that our -- I just want to make sure
that people realize that with the expansion there is again
nothing hidden and what we are looking to do is to store
plastic parts to use in our signs.
We apparently have three trailers.
If you
can see -- if you drive by tonight you will see three
trailers at the back of SRB.
the trailers.
There is no waste stored in
There are brand-new parts to use for our
signs in our other products and we are looking to add that
area to add parts into it.
Another thing that was said is the number
of employees at our facility.
open.
I think that we have been
I see on the presentation here how many people
actually work and live in the Pembroke area.
Other than
Mr. McNab who lives in Arnprior, all of us live in the
Pembroke area.
There is nothing misleading about what we
do.
We still do silk screening, unlike what it says in the
284 presentation, and no waste is stored off-site.
We don't
have another building that we store waste into, so that's a
falsehood as well.
Thank you for the opportunity.
THE PRESIDENT:
Okay, thank you.
We need a break for 10 minutes -- 15
minutes.
15 minutes.
We are getting tired.
Reprise à 17 h 43
THE PRESIDENT:
Okay, we are ready to
proceed.
I would like to move to the next
submission, which is an oral presentation by the Canadian
Coalition for Nuclear Responsibility as outlined in CMD
15-H5.11.
Dr. Edwards, the floor is yours.
285 CMD 15-H5.11
Canadian Coalition for Nuclear Responsibility
DR. EDWARDS:
Thank you very
much, Dr.
Binder.
Can you hear me okay?
Hello, can you hear
me?
THE PRESIDENT:
DR. EDWARDS:
Yes, go ahead please.
Okay, fine.
First of all, I would like to congratulate
the licensee and the CNSC staff for reducing greatly the
emissions of tritium into the environment.
I think that is
certainly something to celebrate.
On the other hand, I think we have to
acknowledge that it was through interventions that these
problems were brought to the attention of the CNSC, which
lead to the monitoring and the work that has subsequently
been done to lead to these improvements.
And this
monitoring is really the direct result, I believe, of
citizen intervention.
As a result, I think that a 10-year
licence is way too long.
I think that there is no way that
this plant should be granted, in my opinion, more than a
two-year licence at a time so that we can see what is
286 happening, we can really see whether these projections that
have been wrong in the past may turn out to be wrong in the
future.
Although we have heard evidence to
indicate that the monitoring is so well done and the
modelling is so well done that it is impossible to be very
far off in the numbers.
I remember quite vividly that just a few
years ago it was discovered that the sister plant, the
tritium light facility in Peterborough, Ontario, the SSI
facility, it was discovered that they had been under
reporting their tritium emissions by an order of magnitude
for something like 18 years.
And that in all those 18
years the CNSC had never caught this.
So it makes me feel uneasy about these
kind of assurances, that the CNSC is so good at their job,
the CNSC Staff is so good at their job, that nothing can
get by them.
I simply don't believe that.
I also think that if there is too long an
interval between licensing intervention periods, then the
Commission does not have a chance to review what the Staff
is doing, what the licensee is doing, and to form their own
judgment as to how well things are proceeding.
So since the Commissioners are really the
ones who are ultimately responsible under law for
287 protecting the health and safety of citizens and the
environment, I do think it is important for them to have
these processes.
Before I go any further I would just like
to put in a couple of factual points.
Earlier it was
mentioned about the permissible level of tritium in Japan.
I have looked at a record from 2014, May 28, 2014, and
apparently it is 1,500 Bq/L.
They had measured 1,700 Bq/L
which was over their maximum limit in one of the monitoring
wells.
So it was not 10,000 Bq/L in Japan, it is 1,500
Bq/L.
I would also like to go on record as
saying that Tritium is in fact a nuclear explosive.
It is
simply not a primary nuclear explosive, that is indeed you
can't build a nuclear weapon with tritium alone.
But the secondary nuclear explosive is
ignited by the primary nuclear explosive and it more than
doubles the explosive power of an atomic bomb, a fission
bomb, and as a result it is the key to miniaturization of
nuclear weapons and therefore the deliverability of nuclear
weapons.
And it is also the key to making the transition
to fission weapons and H-bombs, the fusion weapons.
So I think it is extremely important
regardless of whether it is not in the same category for
sure as plutonium and highly enriched uranium, but it is
288 extremely important.
Now that we have rogue states that
have developed nuclear weapons, but may not have ready
access to tritium, this tritium traffic is very important
in that regard.
Now, I would like to point out that
history has shown that we have made mistakes in the past.
You know, the first example of illuminated dials and so on,
radioactive illumination, was the radium dials of the past.
And they have been phased out, they are regarded now as
having been a mistake.
When I was a kid we had these foot
machines, you could look at your toes wriggling in your
shoes through an x-ray machine.
That has been phased out,
it was regarded as a bad idea as well.
We had lung x-ray machines.
We would pull
into the parking lot at schools and all the people -- all
the children in the school would go through and have a lung
x-ray.
That has been done away with, as regarded as much
more risky than any benefit that it offers.
Radioactive heart pacemakers using
plutonium have likewise been phased out.
So I think that
we have to bear in mind that this whole idea of using
tritium, which is really a waste to begin with, it is a
nuclear waste product of CANDU reactors.
If you go into the OPG website they make
289 it perfectly clear that the only reason they built the
tritium facility was not to create a market for tritium,
but to safeguard the workers and the citizens and the
environment by segregating and sequestering this dangerous
material.
And on their website they say that we are
safely storing it, sequestering it from the environment.
Now we have a private company which with
the licensing of the AECB and then the CNSC is taking this
waste by-product and basically spreading it around.
And
all of it ultimately ends up as waste; it either ends up in
a licensed waste facility or it ends up in a landfill or,
God forbid, it might end up in a nuclear weapons program.
But the fact of the matter is it was
already removed and safely sequestered before.
I think
that in the opinion of the CCNR, the Canadian Coalition for
Nuclear Responsibility, we feel that it was a mistake to
give this company a license in the first place, to liberate
this sequestered waste product and make it into a much more
problematic situation by polluting the local environment
and also polluting distant environments with these
products.
Be that as it may, one thing seems clear
to us, and that is that the City of Pembroke should not
have to bear the brunt of this nuclear radioactive
290 contamination from such a plant.
If the plant could
operate in a more or less hermetically sealed manner, if in
fact the radioactive emissions were truly negligible and
truly exceptional, that they only happened very rarely and
in very small amounts, then one might consider it as a
possibility to operate in a residential area or in a small
community like Pembroke.
But given the fact that by its nature it
is a fairly difficult operation to try and contain this
tritium gas, and so quite a bit of it does escape, it would
be much more appropriate for it to be moved to, for
example, Chalk River.
If that is where the stuff is ending
up anyway, if that is where the licensed facility for the
waste products that are returned are there anyway, why not
have the whole facility there?
So I believe that the CNSC, in its role as
protectors of the public and protectors of the environment,
should be exerting strong pressure on SRB Technologies to
phase out their operations in Pembroke and relocate them to
another site which is more appropriate, maybe adjacent to
the Darling tritium removal plant where they can
incorporate these fabrications right there on site where
the tritium is removed, or at Chalk River Laboratories
where the waste ends up.
But I remember as a professor at Vanier
291 College when the student association approached me and said
they wanted to make Vanier College a no-smoking facility.
I thought, wow, that is going to be very difficult because
so many students are smokers and even the teachers are
smokers.
How are we going to bring about a smoke-free
environment?
Nevertheless, it was done and everybody is
very happy about it, we have a smoke-free environment.
Nobody argued that we should determine
what should be the acceptable number of cigarettes or what
should be the acceptable level of second-hand smoke?
Everybody agreed that we should do away with it, not that
we should have an acceptable level.
And I think that it is common thought in
the medical community that if you have a carcinogenic agent
of any kind, an agent which is cancer-causing or
mutation-causing, that the ideal situation is to have zero
exposure, and that is what one should aim for.
Because contrary to what some of the staff
people have been saying, that you have to have huge
exposures, to perhaps millions of becquerels before you can
have harmful effects, this is simply not a scientific
statement.
In fact, Dr. Muller who won the Nobel
Prize in genetics long ago demonstrated that the harmful
effects of radiation apply right down to the very very
292 lowest levels to single-cell exposure of single nuclear
radiation incidents.
In fruit flies you can have mutations
caused at that level.
Also the BEIR report, not the BEIR VII
report, but the BEIR V report which had to do with
non-penetrating alpha-radiation and deal in particular with
radon gas.
They pointed out that there is no reason
to believe that a single radiation incident with a single
cell could not be a precursor for cancer.
Because we now
know that cancer is usually monoclonal in origin, that is
it begins with a single damaged cell which then replicates
a cancer.
When we hear evidence that some cells are
possibly benefitting from exposure to radiation, I think
these cancer cells would also think that they had been
benefitted because they are very vigorous indeed, they can
reproduce like crazy, but that is exactly what makes them a
cancer.
It is because they are wild cells, they are cells
that reproduce very rapidly and endanger the host's body
that they are in.
So I think that this non-scientific idea
that because a little radiation may be helpful to a large
number of cell that therefore we shouldn't worry about it.
I suppose somebody might have argued from the tobacco
293 companies that maybe a few cigarettes would have been
beneficial.
If you just smoked a few cigarettes and not
too many, perhaps it would be a good idea.
But that is not why cigarettes were
banned.
Cigarettes were banned because they are killing
people.
And radiation is also limited primarily because it
can kill people or cripple them through radiation-induced
cancers and other diseases.
So I do think that the company should be
really strongly pressured to move away from Pembroke and to
move to a facility which is more appropriate for it to be
there.
I also think that the Commissioners should
reflect upon the fact that their role is not only not to
promote nuclear power nor to justify nuclear power, nor to
defend nuclear power, but to defend the public and to
defend the environment.
And consequently, I think the
Commissioners should take a cue from those who have said
that there is no such thing as an acceptable level of
asbestos.
Asbestos should simply be avoided insofar as it
is possible to do so.
That is why they took asbestos out
of brake linings of automobiles, because even small amounts
of asbestos in the air can cause deadly diseases.
MR. LEBLANC:
Ten minutes.
294 DR. EDWARDS:
In a similar way, I think
that the Commission should not be thinking about what is an
acceptable level of exposure to a known cancer-causing
element, but how can we best protect the population when
these exposures are really not necessary.
They don't have
to be where they are and, in fact, perhaps they don't have
to be at all associated with the enterprise that SRB has
chosen to engage in, which is really marketing a dangerous
radioactive waste material.
MR. LEBLANC:
Just for your information,
DR. EDWARDS:
This was always sequestered
Dr. Edwards --
by OPG and taken out of the environment.
Thank you.
MR. LEBLANC:
Thank you.
Well, I was just
going to say that we were way beyond the 10 minutes, but
thank you for concluding.
Thank you.
THE PRESIDENT:
Questions?
Okay, thank you.
Who wants to go first?
Mr. Tolgyesi?
MEMBER TOLGYESI:
I have one, Mr. Edwards.
As you said, it is true that tritium is a
nuclear waste from nuclear power plants.
However, if I use
that kind of analogy for lumber industry, wooden chips are
a waste for lumber industry.
However, this waste becomes a
295 feed for heating.
Does it mean that should this nuclear
waste tritium be stored or under severe regulatory
conditions it could be reused, recycled?
DR. EDWARDS:
Yes.
My answer to the
question is that I think in the case of radioactive
materials recycling is an inappropriate concept.
The three Rs do not apply in the opinion
of the Canadian Coalition for Nuclear Responsibility to
radioactive materials; reducing and reusing does make
sense, but recycling does not make sense if it means
putting it into general commercial distribution, and
especially if it is going to end up in landfills.
We have talked about the hazards to the
Pembroke environment from crushing the glass and letting
the tritium escape.
Well, imagine what happens if these
things end up in landfills.
I do hope that the CNSC will
revisit those regulations and see to it that landfill
disposal of this size is not allowed.
THE PRESIDENT:
M. Harvey?
MEMBER HARVEY:
Dr. Edwards, one of one of
your points is to move the facility.
But at the end of the
day, what would be the difference if we consider that the
releases are controlled, the damages are very limited to
the nearby facilities.
And supposing that the same people
296 would work there, so at the end of the day what would be
the difference?
DR. EDWARDS:
Well, I think the difference
is that it is recognized that in the early days it was
always emphasized that there should be no unnecessary
exposure to atomic radiation unless there is a benefit to
the people who are being exposed.
These people in Pembroke are mostly not
being benefitted by being exposed to the tritium.
Whereas,
you could argue that at CRL, at Chalk River Laboratories,
you do have people who are earning their living as
employees of the nuclear establishment and they are always
being subjected to radioactivity, which the general public
is not being subjected to, as part of their job.
We have to bear in mind that the effect on
pregnant women can be quite severe.
I was present during
the select committee on Ontario Hydro Affairs hearings that
took place in 1979 and 1980 when tritium first came to
public attention.
And one of the people who testified there
was Dr. Edward Radford who was also one of the chairmen of
the BEIR committees.
And he pointed out that if there is a
sudden spike of tritium release such as has occurred, for
example, I know in Peterborough at the SSI Institute there
was quite a substantial release at one particular moment.
297 In five minutes they released a tremendous amount of
tritium.
If this happens during a certain stage of
pregnancy the fetus, especially if it is a female fetus,
can be severely affected by that because the damage she
will carry for the rest of her life.
And so we want to get these kind of
facilities away from ordinary, you know, day to day
families who are just living their everyday lives.
They
shouldn't have to be subjected to this.
MEMBER HARVEY:
Maybe I would like to have
the Staff comment about moving the facility.
the difference?
What would be
What would be the advantages, would there
be some?
MR. RINKER:
So we have a facility that is safe,
emissions are under control, public dose is exceedingly
low.
It is difficult to think of an advantage other than
it may reduce the fear or preoccupation that some
neighbours may have.
MEMBER HARVEY:
MR. LEVESQUE:
Mr. Levesque?
record.
Yes, I think you can understand I have
been asked this question once or twice.
And I can give you
298 a major disadvantage for moving the facility.
Because now
we have a network of 46 monitoring wells, we have a weather
station that we monitor all the environmental data, and I
have been doing it for almost five years now.
And we
understand that ecological system, we understand that
system, that environment.
And to move, to pick-up the facility and
just to move it somewhere else, you are starting all the
way over again.
You know, so there is a lot of work and a
lot of data that you can see that we have done in analyzing
the environment, and how the environment responds to our
emissions.
And that would be to start all over again, and
I don't think in anyone's benefit.
DR. EDWARDS:
On the other hand, the fact
that those installations are there is only for one purpose,
and that is because of the hazards posed by tritium.
If
you moved it to Chalk River, you wouldn't have to worry
about that particular environment that you are dealing with
now and you wouldn't need those monitoring wells and so on.
You have got a different situation at Chalk River.
They
are used to dealing with these materials.
THE PRESIDENT:
If I understand correctly,
there is all kinds of monitoring in Chalk River, all the
buildings, and the Ottawa River, is that not correct,
Staff?
299 DR. EDWARDS:
Absolutely.
THE PRESIDENT:
But the intervenor made
another point, and I would like to hear your view.
If you
are going to stay or like to stay in this facility for a
long time, looks like you got an increasing business, what
about zero emissions?
Can you become an hermetically
sealed organization?
MR. LEVESQUE:
record.
Obviously that is our greatest goal.
Because if we could have zero emissions, there would be
very little discussion today.
It would just be historical.
So it is something we have been working hard on.
As you
can see, I think that we have reduced the ratio of what is
released.
But that is why we want to dedicate 5 per cent
of our revenue to finding emission reduction initiatives.
We are not aware of any technologies right
now that could reduce it to zero, it would be to trap it
and move it somewhere else, and there are dangers
associated with that.
But over a long licence term we can
definitely put our heads to that and dedicate our time to
try to hopefully come back to you and be as close to that
as possible.
THE PRESIDENT:
Questions?
Thank you.
300 The intervenor mentioned the famous
mistake of SSI that was going on for quite a significant
amount of time, both by SSI and Staff.
How can we assure it doesn't happen again?
MR. RINKER:
So there were some regulatory oversight lessons learned.
With that, there was some -- and industry has also learned
from that event, what happened at Shield Source.
And I think we can see that what SRB was
required to do, but they voluntarily increase the frequency
to have a third party annually come in and make sure that
they are their stack is performing and their monitoring of
their stack is being then as they expected it and as they
are reporting.
In addition to that, we now have a IEMP,
Independent Environmental Monitoring Program for which we
have two years of monitoring data, which we have done
independent to the SRB program and we will probably be back
in Pembroke again later this year to relook at this
facility.
And the third line of evidence is the
research that was done on tritium cycling in the
environment often focused on the SRB facility in the past
and in more recent years.
SRB has been very cooperative to
allow us to grow vegetables and grass next to their stacks
301 and to really try to understand how tritium is cycling in
the environment in this area.
So I think as a regulator we have a body
of knowledge that has improved.
As a licensee they have
taken lessons learned from that experience and the
independent monitoring by both the CNSC and that SRB is
employing will avoid this sort of mistake.
THE PRESIDENT:
question.
Thank you. One other
The intervenor on his page 5 argues that SRBT is
exporting material all over the world, including to such
countries as Iran, and do not seem to be carefully tracked
or accounted for.
So first question is, are you shipping to
Iran?
And secondly, would you track this?
MR. LEVESQUE:
record.
No, we used to have a permit to ship to
Iran when it was part of the community, and we did ship
some lights that were used for compasses.
number of years ago.
But that was a
And since then, the relations with
Iran has ceased, and we haven't made an application to
renew that permit, as we are not looking to supply them
anymore.
THE PRESIDENT:
MR. AWAD:
Staff?
302 Actually in 2005 we issued a licence for
SRB to export to Iran about I think 70,000 signs.
And
these 70,000 signs have almost half gram of tritium.
But,
as I said in the beginning, this tritium in dispersed form
is not useable for nuclear weapons.
You need a lot of
technology to remove it and make it available.
And the
threshold really to be useable is beyond three grams of...
And for the question, yes, we are
monitoring every shipment, we have prior shipment
notification, we have -- depending on the licence,
sometimes we have -- after the licence report we have
annual report and we are tracking all the shipments that
SRB is doing.
DR. EDWARDS:
So I gather that CNSC knows
exactly where those 70,000 signs are inside Iran?
MR. AWAD:
No, it is not what I said.
I said, we
send 70,000, but we are tracking by country where the
export is happening.
THE PRESIDENT:
You are also saying that
you do not have a security or a weapon concern about that
shipment.
Is that what you are saying?
MR. AWAD:
very low.
Exactly.
Because .5 grams is
And in dispersed form, which makes it unusable
for any nuclear weapon application.
303 DR. EDWARDS:
I would like to challenge
that statement just on the record.
I don't have a
reference for it, but tritium is tritium.
There is no such
thing as enriched tritium or non-enriched tritium.
Tritium
is tritium.
MR. AWAD:
Raoul Award, for the record.
There is a difference between the
dispersed form of tritium which is used in the light
sources and the pure tritium used in the nuclear weapons.
To get the pure tritium from the dispersed
form there is a very complicated technology which is still
theory, nobody did it until now.
THE PRESIDENT:
Okay.
Questions anybody?
Okay, Dr. Edwards.
DR. EDWARDS:
And so
I will just conclude by saying one thing.
THE PRESIDENT:
Okay.
Just one minute, I
think Mr. Levesque wants to say something here.
MR. LEVESQUE:
I am sorry, I just want to
make sure I clarify something, I am sorry, but they weren't
exit signs, they were small lights, basically the end of
your pencil eraser, and they were used in compasses.
I
just want to get that clarified because that is actually
what it was.
Thank you.
304 THE PRESIDENT:
DR. EDWARDS:
Dr. Edwards, over to you.
Okay.
I do believe that in
order for the public to have confidence in nuclear power
and in the Canadian Nuclear Safety Commission, I think they
have to see that the Staff is not speaking the same
language as the licensee.
And unfortunately time and again, and
today is a good example once more, it seems that the
attitudes of the Staff towards chronic exposures to
radioactive materials is virtually identical to the
attitude of the licensee.
What doe sit matter?
a chronic exposure to a carcinogen.
It is just
What's the problem?
I don't think that is an appropriate
attitude for a body which is supposed to be representing
the public health and safety.
I think that their attitude
should be this is a problem, we don't want to have chronic
exposure to -- unnecessary exposure to a carcinogenic
material.
So I think that until the public can see
that there is a clear distinction in attitude between the
regulator and the licensee that the CNSC will continue to
lose ground as a credible regulator.
THE PRESIDENT:
Thank you.
We would like
to continue and move on to the next submission.
MR. LEBLANC:
Yes.
So we just want to
305 verify if Dr. Judith Deutsch is in the room.
We've been
trying to reach her all day, she was the next intervenor.
If not, her intervention will be treated as a written
submission.
We are now at the stage of going through
the 38 written submissions that we have because that also
includes one from Mr. Zach Ruiter who had been scheduled to
present today and who informed us that he was not able to
do so and that we should consider his submission as a
written submission.
But if you allow me, Mr. President, I
understand that Dr. Newland wanted to clarify a statement
he made earlier with respect to the Participant Funding
Program.
Am I right, Dr. Newland?
MR. NEWLAND:
Yes.
MR. LEBLANC:
Please proceed.
MR. NEWLAND:
Thank you.
Yes, I would
just like to clarify my remarks regarding the availability
of PFP funding for the review of CNSC's annual reports.
Currently PFP funding is not available for
those reports, however, we are undertaking on an ongoing
basis evaluations of the PFP Program to ensure we are
improving the Program and we are considering the
possibility of using the program for such annual reports.
306 Thank you.
THE PRESIDENT:
It was my understanding,
however, that any time somebody can apply for a
research/analysis kind of application to the Program and it
will be considered, because I thought at one time we were
imploring some university faculties to apply to the
Program.
Am I right?
MR. NEWLAND:
record.
To date we have not permitted that for our annual
reports.
THE PRESIDENT:
No, but for any study of
some sort, not necessarily associated with an application.
You're not familiar with that?
MR. NEWLAND:
THE PRESIDENT:
Okay.
Anyhow...
Yes, I think you're right.
You'll have to review
that.
Okay, Marc...?
MR. LEBLANC:
Yes.
If you allow me, I'm
going to go through the list of written submissions
starting with the one from Mr. Zach Ruiter, that would be
15-H5.5.
THE PRESIDENT:
I have to find it.
307 CMD 15-H5.5
Written submission from Zach Ruiter
MR. LEBLANC:
And ask the members if you
have any questions for staff or SRBT on this intervention.
THE PRESIDENT:
Go ahead.
MEMBER VELSHI:
Question for SRBT.
Is
this, as the intervenor says, a technology that is quite
obsolete or is this a growing market with a whole lot of
potential applications?
Where do you see your company
going in the future?
MR. LEVESQUE:
Stephane Levesque, thank
you very much for the question.
We obviously see it as a growing market.
There's a lot of applications that used to use LED lights
or electrical lights that have problems with having
condensation due to water and things like that where they
don't want to use any power source or create a spark, like
in an airplane.
There's also a lot of military
applications for illumination where our product doesn't
generate any heat so it can be detected by heat-seeking
equipment.
We're only a small company so we don't
have a lot of marketing behind us, but we see that if we
308 were able to spend more on that it would be a much more
growing company.
MEMBER VELSHI:
And so what are you
constrained by right now from growing; is it just your
natural growth rate or is it trying to find new markets, is
it your production capacity and equipment constraints?
MR. LEVESQUE:
Stephane Levesque, thank
you very much for the question.
It's a lot of that.
We don't have enough
resources to be able to put it in marketing, to be able to
go to the market anymore and it's steps that we're making,
small steps, but we're one application away from finding a
new way to use tritium light sources, like tritium exit
signs.
Thank you.
THE PRESIDENT:
Anybody else?
Mr.
Tolgyesi...?
MEMBER TOLGYESI:
Just one.
Can you just
tell me, just estimate, in the world market, are you a big
player, small player because it will determine also if you
have potential to grow?
MR. LEVESQUE:
record.
I understand and in the -- we have three parts to
our business.
We have the emergency lighting, which is
309 the exit sign.
From what I understand, we're about three
per cent of the market in that respect in North America.
We're relatively untapped in Europe for signage.
Regarding aerospace, if you talk about
emergency or evacuation exit doors, we're probably at about
75 per cent of the market, but still a little bit to grow
with new.
So pretty well next time you fly in a plane,
more than likely it will be our signs and ones that were
made by our competitors are no longer in business.
Regarding military, it's new applications
that come every day and it's really hard for that one for
us to quantify how many more illumination devices there is,
how much proportion of the market we have.
MEMBER TOLGYESI:
And who are the main,
I'll say, competitors, from where?
MR. LEVESQUE:
record.
Competitors, in each market they would be
different.
They would use either a photo-luminescent based
product and there's been problems associated with that, a
LED product or an incandescent light product.
So there's different technologies, but
they all require either wiring, battery.
And you can think
of applications like in a mine where it's really hard to
get wiring into, a place that handles chemicals where a
spark could generate a major fire, or like I said, the
310 military generating heat, you can be detected, or aerospace
to have more wiring runs just creates more problems in
qualifying the plane.
So there's different technologies other
than the competing ones and sometimes when people have been
using those and find out about our product, they say, I
didn't even know this existed because maybe to us today
we've been talking about tritium lights and it seems
familiar to us, but when you talk to people in the general
population about tritium lights, there's not many people
out there that are aware that that technology exists.
THE PRESIDENT:
But I thought the question
was, are there any other company that produces
tritium-based lights.
MR. LEVESQUE:
record.
Sorry, I didn't understand the question.
There's a company in Switzerland that
produces tritium lights, but their market is focused more
on using tritium lights for applications like watches and
gun sights.
They're not producing any exit signs, aircraft
products or products for the military.
THE PRESIDENT:
Where do they get their
tritium from?
MR. LEVESQUE:
get it from Canada.
My understanding is they
311 MEMBER TOLGYESI:
You were saying that
you're quite present in the aerospace -- in the airplanes.
Lots of airplanes in North America, they are maybe half
Boeing and half they are coming from Europe.
Are your
products used also in the airplanes fabricated in Europe?
MR. LEVESQUE: Thank you for the question.
About 90 per cent of our products are
shipped outside of Canada, mostly to the U.S. and U.K.
If
you just look at the aerospace products which, again, is
about a third of our business, I would say that Bombardier
is pretty well one of the only Canadian manufacturers, De
Havilland, the rest is sent all over the world.
THE PRESIDENT:
MR. LEBLANC:
Okay, thank you.
So the next submission would
have been a submission from Science for Peace or Dr. Judith
Deutsch.
It's at CMD 15-H5.12.
CMD 15-H5.12
Written submission from Dr. Judith Deutsch
sentence.
THE PRESIDENT:
Monsieur Harvey...?
MEMBER HARVEY:
Well, there was only one
In the third paragraph, the middle of the third
paragraph at the end:
312 "There is evidence that the CNSC
failed to regulate, to report tritium
levels, to adhere to subsequent
scientific findings...", et cetera.
So could you just comment on that?
MR. NEWLAND:
record.
I think the evidence is there that we did regulate
and that we took regulatory action, as we showed during our
presentation, at various points during the life cycle of
the plant.
So I reject that.
THE PRESIDENT:
Okay.
I've tried to avoid
it a couple of times, but I think I'd like some staff view
about the ongoing, where we hear a conspiracy theory
between the IAEA and the World Health Organization, this is
in the fourth paragraph.
"...the IAEA effectively gagged WHO
on matters of health in the presence
of ionizing radiation."
We've been hearing this idea that the WHO
is controlled by the IAEA.
DR. THOMPSON:
record.
There's actually an earlier intervention that has
actually, has put in the agreement, it's intervention
15-H5.9A and essentially it's an agreement for
313 collaboration between the IAEA and the World Health
Organization.
I wouldn't qualify this as a conspiracy.
The CNSC and many other organizations have memorandum of
understanding or agreements.
We have one with Health
Canada, for example, Environment Canada and others.
WHO has done a number of studies on the
health effects of radiation.
The IARC, the International
Agency on Research for Cancer is under the WHO, they have
declared radiation to be a carcinogen.
They've done
studies on Chernobyl, on Fukushima, on radon and on many
other aspects.
So I think the WHO has played the leading
role in terms of science in relation to radiation effects.
THE PRESIDENT:
MR. LEBLANC:
Thank you.
So the next submission is
from Mr. Jeff Brackett, CMD 15-H5.6.
Any questions?
--- Pause
MR. LEBLANC:
So the issues raised have
already been addressed with earlier interventions.
The next submission is from Cheryl
Gallant, MP for Renfrew, Nipissing, Pembroke at 15-H5.13.
--- Pause
MR. LEBLANC:
The next submission is from
314 Terry Lapierre, Chief Administrative Officer, the City of
Pembroke, CMD 15-H5.14.
--- Pause
CMD 15-H5.14
Written submission from
Terry Lapierre, Chief Administrative Officer, the City of
Pembroke
THE PRESIDENT:
I'd like to hear from SRB
whether the Municipality and the water and the sewage
section and the health has ever expressed any concern with
you people.
MR. LEVESQUE:
record.
In 2010 there was an individual that
worked at the water waste facility for Pembroke that
expressed some concerns and the concerns were heard by I
think the Ministry of Labour for Ontario and although we
weren't asked to go in the proceedings, we took part and we
proposed to actually do additional monitoring to show this
individual that he wouldn't be exposed to any significant
risk.
We did that and it satisfied the Ministry
of Labour and the City of Pembroke.
315 And we also had an information session
with all the workers at City Hall back around the same time
in 2010 and there hasn't been any concerns expressed since.
THE PRESIDENT:
So when you make a
presentation to the Pembroke Council, is it open to the
public?
MR. LEVESQUE:
for the record.
Sorry, Stephane Levesque,
Yes, it is and we always do it also when
it's televised on a local television channel and they do
that, you know, at certain intervals and we make sure that
it's televised.
We advertise it on our website and, yes,
it's open for members of the public to take part.
THE PRESIDENT:
MR. LEBLANC:
Thank you.
The next presentation is
from the Mayor of the City of Pembroke, Mr. Michael LeMay,
CMD 15-H5.15.
--- Pause
MR. LEBLANC:
The next presentation is a
written submission from the Security Company, CMD 15-H5.16.
CMD 15-H5.16
Written submission from the Security Company
MR. LEBLANC:
Dr. McEwan...?
316 MEMBER McEWAN:
scenario that he mentions.
your presentation.
Sorry, just the mock fire
You briefly alluded to it in
How much of a stress of the whole
emergency system do you think it was; was it very rigorous,
was it -- did it bring up any major flaws?
MR. LEVESQUE:
MEMBER McEWAN:
Bring up any...?
Major flaws or major
issues?
MR. LEVESQUE:
it didn't.
No,
Our response and regulatory requirements we
met, but we identified -- we had a lot of staff that were
involved who also had been independent evaluators for the
City of Pembroke and we identified 38 minor areas of
improvement and a lot of those have already been completed,
but there's nothing major in it, we can say it was a
success.
MEMBER MCEWAN:
So a couple of examples of
the minor areas?
MR. LEVESQUE:
record.
Yes, I think one of the main ones was during the
exercise people that were at the facility, myself, the
incident commander and others that were at the facility
handling the emergency were communicating back with others
that were being directed to a marshalling area through
cellphones and in case there was a problem in
317 communication, we realized and the CNSC staff also made
that recommendation that we should use two-way radios
instead.
So we since purchased two-way radios to do that.
Another thing was, as we were leaving the
facility we didn't have with us a map of the facility to be
able to show the responders.
Although these responders had
toured the facility on several occasions, it would have
been easier to show them to a map, it's right here.
And that's two of the main ones I can say.
MR. LEBLANC:
the Algonquin College, CMD 15-H5.17.
CMD 15-H5.17
Written submission from Algonquin College
THE PRESIDENT:
What is the nature of your
support to the Algonquin College Radiation Program?
MR. LEVESQUE:
record.
We do various initiatives with them.
If you don't
mind, I'll pass this to Jamie MacDonald.
MR. MacDONALD:
the record.
So Jamie MacDonald, for
Our partnership with Algonquin College is long
standing.
We've had a member on the Advisory Board
for the Program for Radiation Safety.
It's a unique
318 program at the College and so we've worked collaboratively
with Algonquin College to make sure that issues pertaining
to radiation safety for a facility such as ours are
considered when they're developing their programs.
We've also hired summer students that have
graduated from the Program.
And as you can see with the
submission, we've even gone to the length of donating
scintillation counters.
MR. LEBLANC:
Colleen Sauriol, Planning and Building Department, City of
Pembroke, H5.18.
--- Pause
MR. LEBLANC:
Josef Allen, CMD H5.19.
--- Pause
THE PRESIDENT:
This intervenor has a very
strong view about some of the criticism.
In here they --
go ahead.
MR. LEBLANC:
the Pembroke Fire Department, H5.20.
--- Pause
319 CMD 15-H5.20
City of Pembroke Fire Department
MR. LEBLANC:
Mr. Tolgyesi...?
MEMBER TOLGYESI:
department.
It's related to fire
When you do your fire drills and emergency
exercise what you did, in the building there are some other
enterprises, you are not the only one.
So are these other
ones included in your emergency drill or fire drill and to
what extent, because you have 250 metres there are private
two houses, to what extent -- how it extends, your
emergency exercise?
MR. LEVESQUE:
record.
I'll answer in two parts.
drills.
First, the fire
Regarding the fire drills, there's no involvement
from any other members of the community, but the next fire
drill that we have, we will be posting it on the website so
that people are aware in the community, if they see a fire
truck at the facility, what's happened.
Regarding the emergency exercise that we
had, it was our first one.
What we did is Vice-President
Ross Fitzpatrick and myself went and met all the agents and
businesses in the community to discuss with them that we
320 were going to do this.
We also mailed and went door-to-door to
the homes within -- the homes and facilities within 500
metres of the facility and basically put out a public
notice to say that we were going to do an emergency
exercise.
We posted it on our Facebook page and obviously
everyone within the Fire Department was aware.
So for this first involvement we didn't
require anyone else to evacuate their facilities, we just
made them aware that we were going to conduct it on that
day.
MEMBER TOLGYESI:
So they were informed
but not participating?
MR. LEVESQUE:
record.
That's correct, for this first exercise.
MEMBER TOLGYESI:
Do you expect that you
will involve them eventually?
MR. LEVESQUE:
record.
Yes, it's something that we've talked internally
about and we think that the next exercise that we plan, we
will involve our neighbours as part of the exercise.
MEMBER TOLGYESI:
Did staff participate or
observe some of this emergency exercise?
MR. CALLIGHEN:
for the record.
Hello.
Mike Callighen,
I am a Licensee Emergency Program Officer
321 with the CNSC.
Yes, we actually had a large contingent of
CNSC staff there, as typical for exercises so we can
observe from several vantage points.
So yes, we did
observe the exercise and I concur with the statements of
Mr. Levesque.
THE PRESIDENT:
While I'm on the subject,
did anybody also check to see that the security of the
facility is adequate?
MR. AWAD:
Yes.
We had a security
inspection recently.
There was an arrangement between SRB
and the local police.
Now, this arrangement is moving to
SRB and OPP, Ontario Provincial Police, because there is no
more Pembroke police and they are now I think negotiating,
them or you, which governs the intervention of the police
in their facility.
Maybe Mr. Levesque could give more
information about it.
THE PRESIDENT:
MR. LEVESQUE:
Go ahead, please.
record.
It's important to understand this
transition.
A lot of the police officers for Pembroke
actually moved over to the OPP.
are familiar with our facility.
So a lot of these officers
322 Nonetheless, we recently met the staff
sergeant for the Pembroke contingent.
facility and had a full plant tour.
He visited our
We asked him if we
could have an MOU with them as we did with the Pembroke
police before.
A couple of weeks ago we were told that
they had a draft that was going to be sent to us any day.
After we see that draft we will be working with them on
completing that, after which we will give a tour to all the
officers, including those that have been at our facility
before.
MEMBER TOLGYESI:
In case of a real fire,
not a drill fire, the firefighters, they are using high
pressure water jets.
Could it break or make damage to your
tubes and eventually have a radiation or could they be
exposed to radiation?
MR. LEVESQUE:
record.
The firemen, when and if they were to
fight a fire at our facility, they would use a selfbreathing apparatus.
So the dose that they would get as a
result of fighting a fire would be little to zero.
But nonetheless one of the actions that we
have identified during the emergency exercise is that as
the fire department entered and they noted that there were
a number of lights that people had been working on to glue
323 on our signs, and so on and so forth.
And it was noted by
one of the firemen that if they were to combat a fire that
could break some of the light sources.
So one of the
actions that we took was to basically have storage units
where the least amount of lights possible would be left on
the floor while we are working, so it's something that we
are looking at.
CMD 15-H5.21
Written submission from Isolite
MR. LEBLANC:
Isolite, H5.21.
THE PRESIDENT:
So what is the nature of
the relationship between you and Isolite?
MR. LEVESQUE:
record.
To understand the relationship, first I
have to explain that Isolite and then Shield Source are
owned by the same group.
So when Shield Source had their
problems at their facility we had a meeting with the
management and owners of Isolite and Shield Source to
basically discuss that there was a possible way that we
could supply them or their sales organization the exit
signs that they required.
One of the conditions and things
324 that were discussed is that what we wanted to make sure is
that everything that happened with their decommissioning
activities would be handled through all the regulations
where they didn't leave the country.
They had no intention
of doing so anyway, but that was one of the conditions.
And also that they would basically open
their doors and show us actually what went wrong had Shield
Source so that we could learn from it, for example these
emission discrepancies so that we could basically learn
from that and incorporate that in our facility as lessons
learned.
So basically if you look at today what the
relationship is, they are just one of our very good
customers and we have a great relationship with them
because they actually know the business inside out having
operated a facility for a number of years and sold those
products.
THE PRESIDENT:
Ms Velshi...?
MEMBER VELSHI:
Did you hire any of their
staff?
MR. LEVESQUE:
record.
The offer was there, but I guess being in
Peterborough and far away from Pembroke it wasn't a
possibility.
325 CMD 15-H5.22
Written submission from Main Street Community Services
MR. LEBLANC:
the Main Street Community Services, H5.22.
THE PRESIDENT:
Dr. McEwan...?
MEMBER McEWAN:
Sorry, I guess this sort of leads to a
slightly broad question.
activities?
How involved are you in community
As we go around we hear of sort of fairly
broad involvement.
Do you see that as part of your
mandate, social mandate with the city and the region?
MR. LEVESQUE:
record.
I think that since Mr. Fitzpatrick and I
have purchased the company from the then foreign owners, I
think that we are two individuals that live in the Pembroke
area.
We have a vested interest in helping as many people
as we can, you know, in as many different fronts as we can
and if we can, you know, afford to do so we will do so and
continue to do so in the future.
It's not really related
to us having a good profile in the community because we
release a quantity of tritium, but it's just something that
is dear to us, being guys from Pembroke and we wanted to
326 help us much as we can.
CMD 15-H5.23
Peter Emon, Warden of the County of Renfrew
MR. LEBLANC:
Peter Emon, Warden of the County of Renfrew.
probably Peter Emon.
It was
I apologize for that.
CMD 15-H5.24
Ron Gervais, Deputy Mayor, City of Pembroke
MR. LEBLANC:
Ron Gervais, Deputy Mayor, City of Pembroke.
CMD 15-H5.25
John Yakabuski, M.P.P., Renfrew-Nipissing-Pembroke
MR. LEBLANC:
John Yakabuski, M.P.P., Renfrew-Nipissing-Pembroke, CMD
H5.25.
327 CMD 15-H5.26 Written submission from Harrington Mechanical Ltd.
MR. LEBLANC:
Harrington Mechanical Ltd., H5.26.
CMD 15-H5.27
Written submission from A. Bucholtz
MR. LEBLANC:
Mr. Bucholtz at H5.27.
THE PRESIDENT:
So this intervenor argued
that it should not be in a residential neighbourhood and I
understand there is a whole new development being proposed
nearby.
Are they all aware of your operations?
MR. LEVESQUE:
record.
Yes, we have done a lot to notify,
especially people within 500 metres of our facility.
They
have had on two separate occasions our pamphlet that I have
discussed today.
They also would have been given that
notice during the emergency exercise and we actually did
some door to door activities to see as many people as we
can and that is something we are going to continue to do in
the future.
328 THE PRESIDENT:
So the developer who is
building the new residential subdivision, if I understand
there is a new subdivision going on, are they informing
everybody that, you know, you exist nearby?
MR. LEVESQUE:
record.
I'm not sure what discussions happen
between the city and the developer.
THE PRESIDENT:
The developer himself is
MR. LEVESQUE:
aware?
record.
I'm not sure, to be honest.
THE PRESIDENT:
I don't know.
Thank you.
CMD 15-H5.28
Written submission from Garry Amyotte
MR. LEBLANC:
Garry Amyotte, CMD 15-H5.28.
CMD 15-H5.29
Written submission from Steel Fire Equipment
MR. LEBLANC:
329 Steel Fire Equipment, 15-H5.29.
CMD 15-H5.30
Written submission from Monika Schaefer
MR. LEBLANC:
Monika Schaefer, 15-H5.30.
THE PRESIDENT:
Okay.
Well, I guess I
will bite.
So there is a statement, the fourth
paragraph, a cucumber sample 4.8 km from SRB contained 117
Becquerels per litre OBT.
How significant is that number?
DR. THOMPSON: Patsy Thompson, for the
record.
Dr. Kwamena is just behind me.
I believe
she has it.
DR. KWAMENA:
Dr. Nana Kwamena, for the
record.
So that number comes from the info report
that we put out from a research study that we did near SRB
in 2008 and 2009 and we published that in the Environmental
Fate of Tritium in Soil and Vegetation and in that report
we calculated the dose as a result of this OBT to HTO ratio
of 15.4.
The doses that we calculated are a fraction of
the public dose limit.
It was .004 milliSieverts and so
330 this is well below the dose limits that are known to have
healthy effects.
This is obviously a theme that we have
said a number of times throughout these hearings, that
although we have these higher than expected ratios, the
dose consequences are much below the public dose limit.
THE PRESIDENT:
Okay.
Would you eat this
cucumber?
DR. KWAMENA:
So as I stated, the dose
consequences from eating this cucumber is well below the
regulatory dose limit and, therefore, I would feel
comfortable eating the cucumber.
THE PRESIDENT:
Thank you.
CMD 15-H5.31
International Physicians for the Prevention of Nuclear War
MR. LEBLANC:
the International Physicians for the Prevention of Nuclear
War, CMD 15-H5.31.
MEMBER VELSHI:
correct for the record.
I just want to get this
The second sentence in there says
that this company on numerous occasions has imported more
radioactive tritium waste from Britain, Russia and the U.S.
than was allowed.
Can you comment on that, please?
331 MR. LEVESQUE:
record.
I got the same thing, Mark.
Thank you
very much.
The things that we have imported from
Britain and Russia and the U.S. were all done with import
licenses describing exactly what we were importing.
I
don't -- I am assuming that the reference to radioactive
waste means product that's expired.
I know that from the
British Ministry of Defence we have received product from
their military that was expired and that we have replaced
and used the parts that we could.
Russia, I don't ever
remember importing any products from Russia.
The only
thing that we have ever imported was a tritium container
because that is another supplier of tritium.
In the U.S., yes, we have imported, you
know, expired exit signs and product from the U.S., but
never have we ever gone over any of those import licenses
and we have reported that to CNSC, based on what the
requirements were at the end of the year or at the end of
the license term.
Thank you.
MEMBER VELSHI:
Staff, do you have
anything else to add to that?
MR. AWAD:
332 No, but just to mention that all the
imports and exports are very carefully monitored.
THE PRESIDENT:
causes me a problem.
You know, that really
This is an Associate Professor of
Clinical Science at the Northern Ontario School of
Medicine, so where does he get this stuff?
MR. AWAD:
Any idea?
We usually publish in our annual report
how many export and import licenses we have and SRB
publishes from time to time what they are importing and
exporting and just looking to all this information you can
construct pieces -- from this information you can construct
any theory.
THE PRESIDENT:
Dr. McEwan...?
MEMBER McEWAN:
And again, just to be
absolutely clear that I understand this correctly, in the
last paragraph, the first sentence of the last paragraph he
says:
"SRB should not be recycling or
reclaiming tritium gas."
(As read)
I am clear, you are not reclaiming the
gas.
You are perhaps recycling the lights themselves?
MR. LEVESQUE:
record.
That's correct.
If you don't mind, if I
333 can maybe answer a bit your question of where this
individual may or may not be getting this information is -and I brought it with me today if you want to have it on
record, but this is the type of pamphlet that is being
distributed in the neighbourhood right next to SRB that
makes these same type of claims and it's signed and it's
listed by, you know, "Contact Ms Kelly O'Grady".
And I
would welcome the Commission to have a copy of it so that
they can see it.
THE PRESIDENT:
Well, since you mention
it, it will be part of the record I assume.
So is it
stated exactly the same kind of -MR. LEVESQUE:
It's very similar.
So if I
give you a copy of it, because I like to -MS O'GRADY:
(Off microphone).
MR. LEVESQUE:
-- I would like to retain
the original, but it is -- it does say "For more
information contact Kelly O'Grady".
So I didn't ask directly if she sent it
out to the neighbourhood, but I know that her name is on
it.
You can have a copy.
I don't think it's totally
different than what the submissions you have been given.
MS O'GRADY:
The information is (off
microphone).
THE PRESIDENT:
We have the CMDs right in
334 front of us.
MS O'GRADY:
(Off microphone).
MR. LEVESQUE:
record.
The pie chart is actually exports, not
imports.
That is actually in our annual compliance report
and discussed at length.
It talks about our exports and
it’s actually our products.
This talks about importing
waste.
THE PRESIDENT:
Okay, thank you.
CMD 15-H5.32
Written submission from Ken Collier
MR. LEBLANC:
Ken Collier, CMD 15-H5.32.
CMD 15-H5.33
Written submission from James Deutsch
MR. LEBLANC:
Dr. James Deutsch at 15-H5.33.
335 CMD 15-H5.34
Coalition for a Nuclear Free Great Lakes
MR. LEBLANC:
Coalition for a Nuclear Free Great Lakes, CMD 15- H5.34.
CMD 15-H5.35
Written submission from Kelly and Roger Goldberg
MR. LEBLANC:
Kelly and Roger Goldberg, CMD 15-H5.35.
MEMBER McEWAN:
So Johnson Meadows, is
that that subdivision that is immediately behind and across
the -- I think it's called the International Road?
MR. LEVESQUE:
record.
Yes, it is.
THE PRESIDENT:
Well, they claim they have
been living -- they say they have been living there for 15
years, so that's not a new subdivision; right?
So they
have no concern with living there for 15 years.
Okay.
336 CMD 15-H5.36
Community Living Upper Ottawa Valley
MR. LEBLANC:
Community Living Upper Ottawa Valley, CMD 15-H5.36.
CMD 15-H5.38
Canadian Nuclear Association
MR. LEBLANC:
the Canadian Nuclear Association, 15-H5.38.
CMD 15-H5.37
Written submission from Darlene Buckingham
MR. LEBLANC:
I probably missed one.
I
missed 15-H5.37, which was a written submission from Ms
Darlene Buckingham.
So were there any questions with respect
to the submission from the Canadian Nuclear Association?
337 CMD 15-H5.39 Written submission from Seiler Instrument & Mfg Co., Inc. MR. LEBLANC:
Seiler Instrument & Mfg Co., Inc., 15-H5.39.
CMD 15-H5.40
Written submission from James Penna
MR. LEBLANC:
Mr. James Penna, 15-H5.40.
CMD 15-H5.41
Written submission from Ed Jacyno
MR. LEBLANC:
Mr. Ed Jacyno, 15-H5.41.
CMD 15-H5.42 Written submission from BETALIGHT B.V. MR. LEBLANC:
BETALIGHT B.V., 15-H5.42
338 CMD 15-H5.43
Written submission from Gilles Provost
MR. LEBLANC:
Le prochain mémoire a été
déposé par M. Gilles Provost, CMD 15-H5.43.
CMD 15-H5.44
Written submission from Dorothy Goldin Rosenberg
MR. LEBLANC:
Dorothy Goldin Rosenberg, CMD 15-H5.44.
CMD 15-H5.45
Written submission from Siegfried (Ziggy) Kleinau
MR. LEBLANC:
Mr. Ziggy Kleinau, CMD 15-H5.45.
MEMBER McEWAN:
Again, I just want to be
absolutely clear, perhaps from staff, paragraph 4:
"Much of the company's production is
exported with those ... lights
eventually falling into the wrong
hands."
Is there any evidence that that is
happening, if indeed there are wrong hands?
339 MR. AWAD:
There is no evidence.
There is no --
and we know who -- what the end-user -- it's one of the
conditions of the license, the end use of it.
And, as I
said in the beginning, it is dispersed form.
Even if it
will go to the wrong hand there is no use for it.
MEMBER McEWAN:
Thank you.
CMD 15-H5.46
Written submission from Jo Hayward Haines
MR. LEBLANC:
The last written submission
is from Ms Jo Hayward Haines at CMD 15- H5.46.
So, Mr. President, you may want to proceed
with the last round of questions.
THE PRESIDENT:
Okay.
So we will move to
the final round and starting with Ms. Velshi.
MEMBER VELSHI:
So over the last few years, the last
licensing period, you have hired a whole lot of new people.
There have been a number of changes to various programs.
In fact, pretty much your entire program seems to have gone
through massive changes and I just wondered how you were
managing the change.
And would you term that your whole
managed system and the programs underneath, at what stage
340 of maturity are they today?
MR. LEVESQUE:
record.
If you -- if you look, I think, on the submission
of -- I'm sorry, on our written submission on page 9 of 72.
And you can see there our -- all our document and
management systems.
There is a number of those programs, I
would say about half, that have undergone significant
changes in the last couple years, but the other half, I
would say, are really mature and have been there for a long
time.
The half that's undergone significant review is
mainly as a result of the -- the new regulatory standards,
the CSA standards, and new regulatory documents that have
been issued.
MEMBER VELSHI:
Right.
And I know, so in
slide 17 you actually list all of those that -- that have
changed and my question was how are you managing the change
given also all the new staff that you have brought on board
in the last little while?
MR. LEVESQUE:
you for the question.
Stephane Levesque.
Thank
We have a number of core staff that
have about 20 years' experience at the facility and those
staff have really mentored and helped with the new staff
coming on board.
And I think I mentioned in my submission
that we have a lot of committee meetings.
A lot of the new
staff have an integral part in each committees, to
341 basically be part of the change.
So staff at all levels is
basically involved with the changes, but we always have
somebody with a lot of experience with them to help them
through it.
MEMBER VELSHI:
So my experience has been
that you actually go through a formal change management
process, part of your management system to make sure that
nothing falls through the cracks and I just wondered if you
were approaching this in a systematic manner.
MR. LEVESQUE:
I'll ask Jamie MacDonald to
complete the question.
MR. MacDONALD:
the record.
So, Jamie MacDonald for
One of the key CSA standards that we're moving
towards implementation is obviously N286-12.
We performed
a gap analysis against our current management system at
that time against those requirements and submitted to CNSC
staff actually as part of the licence application an
implementation plan in order to comply with all the clauses
that apply to us.
That plan currently takes us out till, I
believe, the end of 2016, when we expect to have closed all
those gaps.
We do, for the list of programs that are
undergoing change right now, virtually the same strategy.
So for the training program, it's the -- the same
principle.
We look at the new regulatory document 2.2.2.
342 We assess where we're at as a company and where the gaps
lie, and we develop a plan in order to close those gaps in
the most controlled and safe fashion that we -- that we
can.
MEMBER VELSHI:
Staff, do you have
anything to add to the changed management discipline?
MR. NEWLAND:
Dave Newland for the record.
I just make the observation that they are transitioning to
the CSA standard.
The rate at which they have changed for
a small company I think is appropriate.
And I would also
add that where they brought in people, they have been at
relatively senior positions, and so it wasn't being sort of
like a major reorganization that would really require such
a formal methodology such as that.
MEMBER VELSHI:
Thank you.
THE PRESIDENT:
Monsieur Harvey.
MEMBER HARVEY:
Just one question, it has
been touched a while ago.
It is about the monitoring
equipment to perform a validation of the tritium-in-air
sample collection system (bubblers).
"For the next
licensing period, SRB has committed to annual third party
validation as a result of operating experience from
industry peers."
So is it a new request from the staff or
you decide that by yourself to add yearly independent
validation?
343 MR. LEVESQUE:
record.
As a result of the issues that happened at Shield
Source with respect to monitoring your emissions, we're the
ones that basically developed a plan that included those
yearly verifications.
We were always doing it every two
years, but we thought that doing it yearly will probably
add another level of certainty on our emissions.
MEMBER HARVEY:
It hasn't been initiated
by a request from the staff?
MR. LEVESQUE:
record.
No.
MEMBER HARVEY:
MR. RINKER:
Comments about that?
It's correct, there is a number of areas throughout SRB's
programs where they have voluntarily gone the extra step.
One of those examples we've put in our CMD where we put,
"Their Fitness for Service is fully satisfactory," where
they have implemented a CSA standard for nuclear power
plants in a graded approach way that was not a requirement
but -- but certainly is a step forward to try to do the
right thing and this is another example.
MEMBER HARVEY:
Merci.
THE PRESIDENT:
Dr. McEwan.
MEMBER McEWAN:
On slide 21, I don't think you need to
344 look at it, you identify all your committees, and you have
a Workplace Health and Safety Committee.
Do you have
people from all across the company represented on that
committee?
Sort of people from the shop floor all the way
up.
MR. LEVESQUE:
record.
Yes.
Yes, we do.
We have people that are at all
different levels of the organization.
MEMBER McEWAN:
So if -- if one of the
people who work in your facility feels that they are being
asked to do something unsafe, that -- or something that
they're uncomfortable with, are they able to refuse that
job until it's been discussed with either you or with the
Health and Safety Committee?
Do they have the ability to
rapidly escalate an issue if they don't feel it's been
resolved?
Recognizing you're a very small company.
MR. LEVESQUE:
record.
I say definitely and that's part of the reason why
we've had only one lost injury incident.
We started
ourselves working on the shop floor and we understand
the -- how important it is for us to be listening to the
staff because they're the ones doing the job every day, so,
yes, they have full means and autonomy to do that as part
of the committee.
THE PRESIDENT:
Thank you.
345 Monsieur Tolgyesi.
MEMBER TOLGYESI:
Merci, Monsieur
President.
On page 15 you are saying that you decided
to create a new position of compliance manager, who is
reporting directly to the president.
Now, on page 13 is
organizational chart, he is not responding to the president
but he's responding to the vice president, as any other
director.
Is there something which is ...
MR. LEVESQUE:
record.
I'm sorry for the confusion in that.
mistake on my part.
That's a
When I say directly to the president,
I -- I actually meant senior management, which is comprised
of myself and Ross Fitzpatrick, the vice president.
So,
she reports directly to the two of us.
here.
THE PRESIDENT:
We're going in a circle
MEMBER VELSHI:
Is your operation, like, a
Ms Velshi.
40 hour week operation?
Like ...
What are your operating
hours?
MR. LEVESQUE:
record.
Each employee works 39 and a half hours plus
overtime if need be, but there's different -- there's three
different shifts at the facility that make it so that from
Monday to Thursday people operate between 7:00 a.m. and
346 7:00 p.m.
On Friday currently during summer hours, we call
it, we operate from 7:00 to 4:00 p.m., but during the
winter that would go back 7:00 to 6:30, I think – it's
6:30?
Yeah, 6:30 on Friday.
MEMBER VELSHI:
And you shut -- you shut
down your production when there is precipitation.
So how
many hours a week on average would that be or hours a
month?
MR. LEVESQUE:
record.
That's probably why it was easy for us to ask
customers to give us letters of support and they understand
basically our operations because we've had some orders late
because we've had to stop operating during periods of
precipitation.
There's been some weeks where we've had
very little processing occur.
It's happened sometimes
during certain periods, but we can manage to meet all our
requirements over the course of the year.
Originally when
we imposed that we weren't sure where it was going to lead
us, but we're definitely able to manage it.
MEMBER VELSHI:
But if you were to track
that as your percentage of time you're shut down because of
weather, what percentage of your regular operating hours
would that be?
MR. LEVESQUE:
record.
We don't track it like that because it's really
347 not a concern of us right now.
But if I was to just give
you a gut feel, I would say 75 percent, prorating of the
time.
And that's just a gut feel really.
THE PRESIDENT:
Thank you.
Monsieur Harvey.
MEMBER HARVEY:
You're a small company,
and reading your submission, you -- you hold something like
91 committees last year, which make every three -- three
days, and I suppose the same people appears to many of
those committees.
And how do you manage that?
And do you
have minutes produced for each committee, and to what
extent some of those minutes can be open to the CNSC staff?
MR. LEVESQUE:
record.
We've been able to
manage having the increased number of committee meetings
simply because we've actually looked at it.
We try to not
have one person on too many committees, as to not
overburden them with it.
We have somebody that's fully
dedicated to taking minutes on the committee and that's
their -- part of their full-time job is to do that.
minutes are very extensive.
The
They include findings from the
previous meetings, discussions from that meeting with
actions.
Everyone gets to sign and review those meeting
notes afterwards to make sure they're acceptable to them
before they're formally issued.
And they're posted on the
348 board within the facility for everyone to see.
And that's
the first thing we grab when CNSC staff comes for
inspection because a lot of the things we discuss in
improvements or problems are all documented in those
meeting minutes.
THE PRESIDENT:
Dr. McEwan.
MEMBER McEWAN:
Again, just on staffing, to keep -- to
keep the theme, on page 15 you note that you created a new
position of Manager of Health Physics and Regulatory
Affairs.
I'm surprised that that position came so late and
I'm surprised that you weren't demanding a position like
that much earlier in the process given the issues of the
past.
MR. LEVESQUE:
record.
When I spoke about committees, one of the things I
spoke of initially in the presentation was the Health
Physics Committee.
And I think Mr. Harvey was asking me
how many people were looking after health physics issues
and I answered seven.
Initially I would say not this
licence but the licence before, seven years ago, we had
four people on this committee that had the most experience
working at the facility and most experience in health
physics, including myself, the vice president, and two
other members of our staff with experience, one of which is
349 the compliance manager.
I think that what we found is that
as the company started growing we added a fifth and a sixth
member, and we basically as senior management, Ross and I,
saw the need to really have somebody that would act more as
a coordinator between the tasks that these seven people
were performing.
So there's still tasks performed between
the seven of us, but really Jamie really acts as the
coordinator.
It's something that I or Ross wasn't able to
do anymore as part of management.
It was better to have
somebody solely dedicated for that.
So, that's why we were
able to manage it for so long in that way.
MR. MacDONALD:
Jamie --
MEMBER McEWAN:
Do you have the
independence you need to do the job?
MR. MacDONALD:
Jamie MacDonald for the
record.
Thanks for the question, and, yes, I
certainly do.
Stephane and Ross' door is open all the time
and they have taken any suggestion that I have ever put
forth in the realm of health physics, and the team as a
whole have complete licence to make recommendations and
changes where we see fit to make that radiation doses are
as low as reasonably achievable.
MR. RINKER:
So I would concur that the -- the work -- or the job of
350 what Mr. MacDonald does now was shared and was completed in
the past, but, as in a number of areas, SRB did an
organizational chart review a number of years ago and
recognized some key positions that would supplement how
they would implement their programs and what you see here
is a result of that.
THE PRESIDENT:
Mr. Tolgyesi.
MEMBER TOLGYESI:
On page 17 you -- you
are talking about committee meetings, 91 altogether, but -so you mentioned specific committees, but there is
something other and that is the highest number of meetings.
What's that other?
MR. LEVESQUE:
record.
I totally understand the question.
It's these
meetings that really don't fall in another category.
Because sometimes we sit there and we say -- because it's
four of us, it's not necessarily about waste, it's not
necessarily about this, let's call this a other committee
meeting.
It's one that doesn't really fall within the
other categories, but it's more or less controlled in the
same way, with meeting minutes taken by the same
individual, as discussed, having actions and having reviews
just like all the other ones, and they're also posted.
THE PRESIDENT:
Ms Velshi.
MEMBER VELSHI:
In your slide on
351 performance assessments, you mentioned that in the last
licence period OPG conducted three audits.
So as your
supplier, what was the scope of their audit?
And does it
overlap with what the CNSC may be looking at as well?
MR. LEVESQUE:
Just one moment.
Stephane Levesque for the record.
for taking a little bit of extra time.
miss anything.
Sorry
I didn't want to
During those three audits what was reviewed
is listed on page 21 of our written submission.
It was our
operating licence to make sure that we had a valid
operating licence to process and possess tritium; our
operating procedures involving tritium; our inventory
control records; the storage, use and handling of the
isotopes; the training activities; the physical security
measures that we took at the facility; the staff monitoring
procedures, and the instrument calibration and tritium
accounting.
So, yeah, all lot of these things are also
verified by CNSC staff, but they do a different way; they
don't look at it as a safety control area.
THE PRESIDENT:
Monsieur Harvey.
Dr. McEwan.
MEMBER McEWAN:
So one question related to
the 5 percent that you're going to commit to research, I -that's clearly a laudable goal and -- and there are
obviously opportunities for you there, both for
352 improvements and for innovation.
it?
You're a small group.
How are you going to do
You're a small firm.
Are you
going to do it internally, you're going to contract with
universities, colleges?
Are you -- I'd just be interested
to know how you -- if you have a plan for building that.
MR. LEVESQUE:
record.
We were hoping that if we were issued a 10 year
licence based on those numbers, that we would have no
problem having a minimum of 5 percent, and we were looking
at using a combination.
I think we spoke about we have an
individual that's an independent contractor that works at
the facility that has over 30 years' experience.
He was
going to visit different establishments to see what they
knew.
He was going to do that with our Manager of Health
Physics and Regulatory Affairs to see what those people
knew about different technologies on how to reduce
emissions, and that was going to include, you know, people
like the University of Ottawa, who are heavily involved
in -- in tritium monitoring, and it was going to involve
different contractors and different government facilities.
THE PRESIDENT:
updates on progress on this?
So, can we get periodic
Because one of my questions
would be what can we expect -- when is the next annual
report for SRBT?
MR. RINKER:
353 The scheduled date, there's two days, the agenda is not
published, but September 30th to October 1st.
THE PRESIDENT:
MR. RINKER:
September the 30th.
Or October 1st, two days.
THE PRESIDENT:
Okay.
So at that time we
would expect, I guess, updates from a lot of things we've
been discussing here.
I would -- sure would love to hear
periodically about how you're doing on this research.
MR. LEVESQUE:
record.
Yes, for sure that was something that was planned
is to have as part of our Annual Compliance Report and
obviously we want to share that with members of the public
who have concerns, so we'll definitely highlight anything
that we found or was able to develop during each year.
THE PRESIDENT:
Thank you.
Monsieur Tolgyesi.
MEMBER TOLGYESI:
On page 25 you are
talking about training and you are saying that there are
written tests conducted following an annual radiation
protection training.
And what happens to those individuals
who are not obtaining the pass criteria of 75 percent,
that's what you are demanding?
MR. LEVESQUE:
record.
I'll pass that question to Jamie MacDonald.
MR. MacDONALD:
354 the record.
During the annual training session we
administer testing.
Should an employee fall below the
pass/fail criteria, typically with the annual training it's
an all-day event and they wouldn't get that feedback
immediately, but the next opportunity that employee, we
would sit down, go over the parts of the test that would
have been missed, reinforce to make sure that the
understanding of the concepts are there, and re-administer
testing to have confidence that this person is fully
qualified to continue on working in the capacity that they
do.
MEMBER TOLGYESI:
And are you testing only
the fields which he missed or you administer a new full
exam?
MR. MacDONALD:
record.
Jamie MacDonald for the
That hasn't happened yet, I guess I should say.
We've tested this year was the first year that I conducted
it in this room actually and we had a 100 percent pass
rate.
So, we haven't explored whether or not we would test
with a new test.
Yeah.
So, we would -- I'll just pass it
to Stephane.
MR. LEVESQUE:
Yeah, if can just add for a
few more years of information, thank you, before that.
When we had people that didn't meet the 75 percent failure
rate -- I'd like to add that the test is given to all
355 individuals, even those that don't work with tritium.
And
why we do that, because there are some people that will
never work in the areas with tritium, is because we think
people are interested in knowing, it's good for us to know
and they're ambassadors for our company.
So, they can go
elsewhere and tell people and meet other people that can
teach people in the community.
But we've had some people
in the past that weren't working with the isotopes that
failed the test and I basically give them a new test, but
testing roughly the same things but a completely different
test.
So, not the same question.
MEMBER TOLGYESI:
And these tests are
restricted to those in the radiation protection or in all
other fields?
MR. MacDONALD:
the record.
The annual radiation safety training that we
administer is given to 100 percent of the staff that work
with our facility, from Stephane's level all the way down.
MEMBER TOLGYESI:
It's only regarding
radiation protection, there's no other
MR. MacDONALD:
test?
There have been elements
that we have tested questions in quality management, for
example, testing on knowledge and awareness of our
nonconformance process, but the lion's share of the test
questions that we would administer are relevant to
356 radiation protection in our facility.
THE PRESIDENT:
Thank you.
Ms Velshi?
MEMBER VELSHI:
There was a question asked
earlier that we didn't get around to getting to the answer,
which was the level of effort required for you to prepare
for these licensing hearings, if you can share that with us
along with any benefits that come as a result of
participating in one of these.
I'm sure there must be
some.
MR. LEVESQUE:
For the record, well, one of the benefits
I can see is that we notice that some members of the public
don't seem to express themselves until the licence hearing,
and we're hoping to change that.
And that's something
we're going to try to promote and to push people, say do
you have any questions, do you have any concerns, so that's
one positive.
And regarding the effort required for a
small company like us to go through licensing, it's really
a lot of work.
It's astronomical.
There's a lot of us that have to dedicate
our time to being able to produce the documents that you
see in a way that's presentable to yourselves, to members
of the public who may not have all the information on the
357 facility, so there's a lot of thinking involved, a lot of
revisions, a lot of things to do.
If it was just a matter of rehashing the
same data as our annual compliance report, it wouldn't be
so bad, but the application process and the putting
together the specific documents for people to see, I think,
is really time consuming.
MEMBER VELSHI:
Can you put a number of
full-time equivalents to that?
MR. LEVESQUE:
It's Stephane Levesque, for
the record.
It's in the hundreds of hours.
And if --
if you look at we hired, I would say, about a year and a
half before today Mr. MacDonald as a manager of health
physics and, at the same time, coincidentally, Mr. McNabb
as a consultant, we could not have done it with the five of
us that were in the health physics team.
You know, we
definitely needed those two individuals to be able to do
all the paperwork required to go through the licensing
process to relieve me to do other things like public
relations, so on and so forth where before I would have
been involved in doing that.
And that's why I'm saying that with the
time that, hopefully, we would have with a longer-term
licence, we could dedicate that to finding ways of reducing
358 emissions which we do all the time anyway, but it would
give us a lot more time to do that.
THE PRESIDENT:
Monsieur Harvey?
MEMBER HARVEY:
One last question.
When establishing the financial guarantee,
are you taking into account the groundwater contamination
and the -- some reclamation that could be required and will
the -- all the wells will stay there and will be followed
for a certain number of years?
MR. RINKER:
So reclamation of tritium in the
groundwater is not considered in the cost estimate, but
decommissioning of all of the wells would be, yes.
THE PRESIDENT:
Or is there enough funds
now in the kitty or about to be replenished to do the job
of decommissioning?
MR. RINKER:
The short answer is yes, and their
preliminary decommissioning plan was recently reviewed.
How the cost estimate was determined was determined
accessible to staff.
MEMBER HARVEY:
yet.
But the money is not there
I mean, it will be there during the next three years.
THE PRESIDENT:
Well, 500 -- I don't
remember the exact number now -- is already there.
359 MEMBER HARVEY:
Yeah, yeah, that's right.
But the $100,000 is not there -- not yet there.
MR. RINKER:
That is correct, so the majority of the
money is in place and, with some lessons learned from a
facility that went through a similar decommissioning, I
would -- you know, it's hard to say what would -- if it was
to close tomorrow and all the money wasn't there what would
happen, but I think considering the performance of this
facility and the fact that more than enough money is
available to put the facility into safe state and to
restore it, it's a reasonable plan.
MEMBER HARVEY:
Merci.
THE PRESIDENT:
Dr. McEwan?
MEMBER McEWAN:
Again, final question, I think for staff.
This is a sort of question that we skirted a little bit
earlier.
This is a relatively complex facility in
small volume in a leased facility.
Does the fact that it
is a leased and not an owned facility create any licensing
or regulatory issues, and is there any linkage in any way
to the actual owner of the facility, Mr. Harrington?
MR. RINKER:
So this does not raise a concern with
360 staff.
There are many licensees that do lease their
facilities.
Should there be an issue that SRB leaves
town, they live here, unlikely, but the landlord is -ultimately would be responsible and we have powers of order
to ensure that they would take over.
MR. LEVESQUE:
record.
I just want to add that our landlord's
been intimately involved with our licensing throughout the
years.
They've been the landlord for a number of years.
They realize that there's a financial guarantee that's in
place, that we're looking to replenish, to top up.
They've been at the facility.
understand.
They
They wrote that letter of support for the
licence hearing.
They're well aware of their
responsibilities.
THE PRESIDENT:
Mr. Tolgyesi?
MEMBER TOLGYESI:
My last question is, I'm
going back to the fire protection.
In the building --
you are sharing a
building with some other ones -- is there a fire wall
between you and your neighbours so if it's a fire in your
place it doesn't expand or it delays the expansion of a
fire so the firefighters could intervene?
361 MR. FITZPATRICK:
Ross Fitzpatrick, for
the record.
Yes, there is a fire wall in place and
also, with the new expansions coming in place, the whole
building is now sprinklered.
THE PRESIDENT:
Ms Velshi?
MEMBER VELSHI:
My last question to staff.
There's a lot of concern, misinformation
about the facility and the waste management aspect of it.
So in the annual report -- and I don't know if it normally
includes that, but I think it would be helpful if there's
more detail provided on not only the number of shipments,
but at the volume both from the processing as well as from
signs that had been received and how much of that has
resulted in waste.
I think it may bring in more light to
exactly how much of the business is waste as opposed to
actually producing the inspections.
MR. RINKER:
I think we recognize that the purpose of
the annual report is to explain performance to the
Commission but also to the public, so we've heard the need
to make sure that our understanding of groundwater is
recovering, so we'll increase the data presence in that and
also, I think, on the waste inventory.
362 THE PRESIDENT:
So on that particular
item, on the groundwater, you know on your page 32, you
have one of those charts that I really like.
I'd like to
see in the annual report continue.
To me, this is measuring all the wells all
the way to the Muskrat River and, as you know, I like those
little blue almost invisible little numbers that, as far as
I was concerned, look like gradients, movement, plume
movement.
I'm reading into it all kind of things.
So over time, hopefully, that will allow
you to refine your model as to whatever happens, it's the
outcome at the river that matters, right.
So we want to
know not only the surface, but also deep what goes into the
river.
And hopefully, we can model that a little
bit more and keep track of it as we get more and more data.
Is that reasonable?
MR. RINKER:
So Mike Rinker, for the
record.
We agree, and last year's report did
contain this, so we'll continue to update this figure, but
we'll also show some explanation that those lines are
groundwater contours, not tritium contours, so they show
the direction of which groundwater is flowing if you're a
363 hydro geologist, so we'll put some explanation around what
those lines mean.
THE PRESIDENT:
But if that's where the
water is slowing, I assume the tritium flows with the
water.
MR. RINKER:
We need to put some context
there because it's flowing so slowly that by the time it
would reach the Muskrat River, it's likely going to decay
to near -- to almost immeasurable numbers.
THE PRESIDENT:
But that's your safety
argument.
MR. RINKER:
That's our safety argument.
And -- but it's not just surface water that we're concerned
with.
It's actually the groundwater itself should somebody
put in a well, access it for some reason in the future for
drinking water or something.
We want to make sure the
groundwater itself is protected.
THE PRESIDENT:
So you will keep us
updated on -- in the annual report on this.
MR. RINKER:
Yes, we will.
MEMBER McEWAN:
Could I just --
THE PRESIDENT:
Go ahead.
MEMBER McEWAN:
It would have been very,
very helpful on this map also to clearly identify where
that housing development is to -- I'm not sure where it is
364 other than sort of looking, I think, north is to the left.
Southwest.
Looking southwest of your facility.
It would be very helpful to have that put
on the map, too.
THE PRESIDENT:
Okay.
Whose turn is it
now?
Anybody has any other question?
Okay.
No?
I have just two quickies.
Are all employees undergone by us a
testing -- urine tested, all employees?
How frequently do
you do this?
MR. LEVESQUE:
record.
Yes, all employees go urine test.
It's
every week for those that work in Zone 3, so that's the
zone where tritium is processed, and every two weeks in the
other zones.
THE PRESIDENT:
find any detectable numbers?
So they have -- you ever
I noticed that in the LCH
there is 1,000 becquerel per millilitre for any sampling
period.
This is the action level.
Has that ever been exceeded?
MR. MacDONALD:
Jamie MacDonald, for the
record.
That action level has not been exceeded as
365 far back as I can go.
I know for sure it was not exceeded
during the previous licence period.
Routinely, of course, we will detect
tritium in our employees that work in the active area, and
that is the input into our dose calculations that we've
reported to you here today, so we do see positive tritium
in urine, but the doses that result from that are very
controlled and very low.
I'd like to say, you know, if we can -our goal as health physics team is to try and have
everybody at peak production fall below the public dose
limit, so that's kind of what the team has decided to
strive for.
THE PRESIDENT:
MR. LEVESQUE:
Go ahead.
If I can just add a little
bit of history, we remember that the last time somebody
exceeded the 1,000 was in the late nineties, so just to put
some perspective in it.
It hasn't happened since.
THE PRESIDENT:
So my last question, just
out of curiosity, on your Licence Condition Handbook on 39
of 61, there's something called chart recorder measurement,
10,000 microcurie per metre cubed.
MR. MacDONALD:
What is this?
record.
So as well as doing sampling of our
366 emissions through our bubbler systems, which is the
emission of record that we use -- we sample those each
week -- we also have a system that we call the real time
stack monitoring system.
And so in real time, we have tritium air
monitors monitoring the concentration of tritium that goes
out our stacks.
And those outputs are hooked up to chart
recorders.
On the chart recorder that the action
level of 10,000 microcurie per cubic metre, that's
basically at the top of the scale.
And so if we were to be
in the condition where there was an emission of that
concentration exceeding a duration of an hour, we would
have exceeded an action level and that would require us to
perform an investigation, perform a root cause analysis and
address the problem and also report to CNSC staff all of
those items.
THE PRESIDENT:
But since we've been told
there is no dosimeter for tritium, how reliable are those
monitoring?
Are they immediately they will detect an
exceedance, or is it a period that you have to go -- do
bells ring, something rings, flashing light?
MR. MacDONALD:
What goes on?
record.
During our processing operations, it's
367 part of the procedure for staff to be continually checking
those emissions.
They aren't necessarily hooked up to a
physical alarm system, but they respond very quickly to any
process upsets that we'd have within a matter of 10, 15
seconds.
And so the responsiveness of the people
that are doing the processing is very speedy, but if -THE PRESIDENT:
there's no alarm.
Is it visual or is it --
Why are there no alarms?
I mean, I thought human beings did not
tend to look at devices, et cetera, et cetera.
MR. MacDONALD:
So Jamie --
THE PRESIDENT:
That's why co-pilot has
MR. MacDONALD:
Yeah, Jamie MacDonald, for
alarms.
the record.
It is a visual system that we utilize, and
it doesn't have an alarm hooked up as it is today.
THE PRESIDENT:
MR. LEVESQUE:
Staff?
Sorry.
If I could just add
a little bit on that.
So our operating procedures, as our
process takes place, requires the staff actually to look at
the chart recorder on numerous occasions.
And the process
that they perform, they know right away if something
368 happened within the system and they look right away at the
chart recorder.
THE PRESIDENT:
Well, again, my
observation is that you've got so many monitoring spots
from stack to et cetera, et cetera, I don't rely on human
being interface.
Human-machine interface is the cause of
most failures.
It would be nice if there was some trigger
that alert them.
MR. LEVESQUE:
suggestion.
Yeah.
Thank you for the
That's something we can definitely look into.
THE PRESIDENT:
Okay.
Any other -- staff,
you want to comment on that, by any chance?
MR. RINKER:
I think just in general, there are -- our
radiation protection program for workers is quite good, but
that's a reasonable suggestion for improvement.
THE PRESIDENT:
Somebody going to disagree
with us.
MS MacDONALD:
Sheri MacDonald, for the
record.
I'm not sure this is the information that
you're looking for, but in terms of worker protection,
there are tritium and air monitors in the facility that
continuously the air concentrations of tritium, so they do
369 alarm if the concentrations are elevated so workers are
aware and react accordingly, so they are protected.
I'm not sure if that's the same -THE PRESIDENT:
How are they alarmed?
Is
the alarm -MS MacDONALD:
They are alarming.
They
are alarming.
THE PRESIDENT:
Because I was told they
are not.
MR. LEVESQUE:
It's Stephane Levesque, for
the record.
That's a room monitor for the area that
they work in, and I think what we're referring to is it's
monitoring the actual stacks for the emissions, so it is
two different things.
MR. MacDONALD:
record.
And I'll certainly say that Sheri is
correct.
We have monitoring throughout the facility, and
they have alarm set points set very low that can tell us
very quickly if there's an upset condition at a very low
level so that all of our staff can react according to their
training.
MR. JONES:
Hi.
Mike Jones, environmental
project officer, CNSC, for the record.
370 I just wanted to point out that the action
levels that do correspond to the release limits for the
facility are actually linked to the bubbler system, so in
addition to what we're discussing now, there are fixed
action levels that are -- you know, we -- they are looked
at on a weekly basis when the bubbler values are obtained.
And the chart monitor would be like a secondary way of
determining whether an action level for the air emissions
exceedance had occurred.
THE PRESIDENT:
Okay.
Thank you.
I think that this concludes the hearing.
Right?
You have the last word.
MR. LEVESQUE:
Thank you very much for
your time and the opportunity to be able to answer some
questions and make additional comments, but thank you.
THE PRESIDENT:
Okay.
Thank you.
So Marc, any closing remarks?
MR. LEBLANC:
Just if anyone borrowed some
interpretation devices, please return them so you will have
your driver's ID returned to you.
Thank you, and safe travels.
--- Whereupon the hearing adjourned at 7:43 p.m. /
L'audience est ajournée à 19 h 43

Transcription de l`audience du 14 mai 2015

Transcription

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